Willits City Council
October 8, 2025

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
within the MH zoning district that may be proposed in the future is anticipated to be comparable to, and possibly less than, the Project due to the importance of water in the log yard for keeping logs wet during storage. Details on the specific locations, capacities, and dimensions of the ponds and/or other water storage facilities would be subject to grading and/or building permits through the City. A less than significant impact would occur.

X.c.i) The Project and other typical industrial facilities would not alter the existing drainage pattern of the Site in a manner which would result in substantial erosion or siltation on- or off-site. Construction activities would be subject to the standards of the CGP, which requires the preparation of a SWPPP with BMPs designed to prevent, at a minimum, erosion resulting from construction activities and minimize the discharge of sediment and other pollutants associated with construction sites. Following construction, runoff and stormwater flows would be managed by adhering to the post-construction requirements of the CGP. Additionally, industrial facilities such as manufacturers, landfills, mining, steam generating electricity, hazardous waste facilities, transportation with vehicle maintenance, larger sewage and wastewater plants, recycling facilities, and oil and gas facilities would also be subject to coverage under the IGP, administered by the SWRCB. Through compliance with the CGP for both the proposed Project and other typical industrial facilities and the IGP for other typical industrial facilities, substantial erosion or siltation would not occur, and there would be a less than significant impact.

X.c.ii-iii) The Project would not substantially increase the rate or amount of surface runoff in a matter which would result in flooding on- or off-site, create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems, or provide substantial additional sources of polluted runoff. Post-construction stormwater would continue to infiltrate as the Project does not propose the introduction of impervious surfaces. Additionally, as discussed above, the increased water output from the irrigation system is anticipated to cause ground saturation and overland flow, which would be captured by a series of drainage ditches to direct flow back to the holding pond. As such, although the proposed Project would alter the drainage pattern of the Site, it would not impact off-site runoff and would not result in on- or off-site flooding. A less than significant impact would occur.

Although other typical industrial facilities would have the potential to alter the drainage pattern of the Site, this would not be anticipated to result in on- or off-site flooding. Construction activities would be subject to the standards of the CGP, which requires the preparation of a SWPPP with BMPs designed to prevent, at a minimum, erosion resulting from construction activities and minimize the discharge of sediment and other pollutants associated with construction sites. Following construction, runoff and stormwater flows would be managed by adhering to the post-construction requirements of the CGP. Additionally, industrial facilities such as manufacturers, landfills, mining, steam generating electricity, hazardous waste facilities, transportation with vehicle maintenance, larger sewage and wastewater plants, recycling facilities, and oil and gas facilities would also be subject to coverage under the IGP, administered by the SWRCB. A less than significant impact would occur.

X.c.iv) As discussed above, the majority of the Site is designated as an area of minimal flood hazard (Zone X, unshaded). However, the eastern portion of the Site is designated as the 100-year flood (Zone AE) and the 500-year flood (Zone X, shaded). Part of the Project would be located within the 100-year flood and the 500- year flood, including the log decks on the eastern portion of Qual Meadows, drainage ditches, and water storage ponds. The proposed Project would not impede or redirect flood flows, as the Project would not introduce impervious surfaces and room would exist between log decks for flood water to flow in the event of a flooding event. A less than significant impact would occur.

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
If development of other typical industrial facilities should occur in the flood zone for future projects, future industrial facility operators would obtain a Flood Zone Development Permit from the City, as needed. A Flood Zone Development Permit would ensure that typical industrial facilities would be designed in a way that would not impede or redirect flood flows. A less than significant impact would occur.

X.d) While a portion of the Site is located in a flood hazard zone, as described above, it is not located in a tsunami or seiche zone, as it is not located near any large inland bodies of water and is approximately 25 miles east of the Pacific Ocean. Portions of the proposed Project are located within the flood zone, including some of the log decks, drainage ditches, and water storage ponds. Although portions of the proposed Project would be located within the flood zone, the Project would not risk the release of pollutants due to Project inundation. As the log decks would consist of untreated wood, and the ponds and drainage ditches would consist of irrigation water, these Project components would not pose a risk to release pollutants to the environment. A less than significant impact would occur.

If development of other typical industrial facilities should occur in the flood zone for future projects, future industrial facility operators would obtain a Flood Zone Development Permit from the City, as needed. A Flood Zone Development Permit would ensure that typical industrial facilities would be designed in a way that would not risk the release of pollutants due to inundation. A less than significant impact would occur.

X.e) As discussed above, the Project and other typical industrial facilities would be required to comply with the Statewide CGP and the City Standards, updated November 12, 2011, which would require preparation of a SWPPP, including identification and implementation of BMPs to be utilized to minimize the amount of sediments and other pollutants from being discharged in stormwater runoff. Additionally, industrial facilities such as manufacturers, landfills, mining, steam generating electricity, hazardous waste facilities, transportation with vehicle maintenance, larger sewage and wastewater plants, recycling facilities, and oil and gas facilities would also be subject to coverage under the IGP, administered by the SWRCB. Compliance with these regulations would facilitate the implementation of water quality control efforts at the local and state levels. There is currently no sustainable groundwater management plan for the Basin; however, the LLVGWMP was adopted by the City on August 26, 2020. As all impacts from the Project and other typical industrial facilities on hydrology and water quality are anticipated to be less than significant, they are not anticipated to conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan. A less than significant impact would occur.

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed Project and other typical industrial facilities would have a Less Than Significant Impact on Hydrology and Water Quality.

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
XI. LAND USE AND PLANNING. Would the project: Potentially Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Physically divide an established community?
b) Cause a significant environmental impact due to a
conflict with any land use plan, policy, or regulation
adopted for the purpose of avoiding or mitigating an
environmental effect?

DISCUSSION
The Site has a land use designation of C-G per the Willits General Plan 2020 (1992). Quail Meadows has a zoning designation of C2, pursuant to Ordinance No. 90-13 adopted by the Willits City Council June 13, 1990, and APN: 108-040-18 has a zoning designation of C1 according to the City of Willits Zoning map dated May 2010. The Applicant requests a GPA and Rezone to change the existing land use and zoning designations of the Site to M-G and MH, respectively, to facilitate expansion of an existing log yard operation. See Figures 3 and 4: General Plan Amendment Figure and Rezone Figure, respectively. Additionally, the Applicant requests a BLA to retain an approximately 2.2-acre portion of APN: 108-040-18 along N Main Street for future commercial use. The approximately 2.2-acre parcel would maintain the C-G and C1 land use and zoning designations, respectively, and would not be included in the proposed GPA and Rezone (see Figures 3 and 4). See Figure 5: Site Plan for the approximate location of the proposed BLA.

Surrounding uses include the GlenMark Self Storage adjacent to the west of the Site, the existing log yard adjacent to the south, railroad tracks within the GRTA right-of-way adjacent to the east, the Highway 101 bypass to the northeast, and residential structures on parcels with a land use designations of M-G and R-L and zoning designation of Limited Industrial (ML) and R1 to the southwest. Nearby uses include N Main Street (previously Highway 101) and commercial uses to the west, Willits High School to the south, industrial uses to the east, and undeveloped agricultural land to the northeast. Table 7, below, provides additional information on the surrounding land use and zoning designations, as well as existing uses.

Table 7. Surrounding land use and zoning classifications Direction Land Use Zoning Existing Land Uses
Northeast AG (Agricultural) AG (Agricultural) Highway 101 bypass, undeveloped agricultural land
East Industrial-General (M-G) Heavy Industrial (MH) Railroad tracks, industrial uses South Industrial General (M-G);
Public Service (PS)
Heavy Industrial; Public
Facility (PF)
Existing log yard, Willits High
School
Southwest Industrial General (M-G);
Residential – Low Density
(R-L)
Limited Industrial (ML);
Single-Family Residence
(R1)
Residential structures
West Commercial General (CG)Heavy Commercial (C2) GlenMark Self Storage, N Main Street, commercial uses
XI.a) The proposed Project would not physically divide an established community as the Project would introduce industrial uses to the Site, which would be consistent with industrial uses to the east and south.

Additionally, the proposed GPA and Rezone would be consistent with the surrounding land use and zoning designations to the east and south. As a result, a less than significant impact would occur.

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
XI.b) Neither the Project nor other typical industrial facilities would cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. As discussed above, the Site has a land use designation of C-G, and Quail Meadows and APN: 108-040-18 have zoning designations of C2 and C1, respectively. The proposed GPA and Rezone would change the existing land use and zoning designations of the Site to M-G and MH, respectively. This GPA and Rezone would be consistent and compatible with surrounding land use and zoning designations, as land to the east and west of the Site has a land use designation and zoning designation of M-G and MH, respectively.

Since the proposed Project and other typical industrial facilities would be consistent and compatible with surrounding uses and the proposed land use and zoning designations are consistent with surrounding designations, a less than significant impact would occur.

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed Project and other typical industrial facilities would have a Less Than Significant Impact on Land Use and Planning.

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
XII. MINERAL RESOURCES. Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Result in the loss of availability of a known mineral resource that would be of value to the region and the
residents of the state?
b) Result in the loss of availability of a locally important mineral resource recovery site delineated on a local
general plan, specific plan or other land use plan?

DISCUSSION
According to the Mineral Land Classification Studies Index of the California Department of Conservation [DOC, 2015 (b)], the Site is not located in an area with known mineral resources. Additionally, there are no known mineral resources of significance on the Site. Furthermore, the Site is not utilized for Surface Mining and Reclamation Act (SMARA) activities.

XII.a-b) As discussed above, the Site does not contain mineral resources that are of value locally, to the region, or to residents of the City, County, or state. Additionally, the Site is not identified as a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan.

Therefore, neither the Project nor other industrial facilities would interfere with materials extraction or otherwise cause a short-term or long-term decrease in the availability of mineral resources. No impact would occur.

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed Project and other typical industrial facilities would have No Impact on Mineral Resources.

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
XIII.NOISE. Would the project result in: Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Generation of a substantial temporary or permanent
increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable
standards of other agencies?
b) Generation of excessive groundborne vibration or
groundborne noise levels?
c) For a project located within the vicinity of private airstrip or an airport land use plan or, where such a
plan has not been adopted, within two miles of a
public airport or public use airport, would the project expose people residing or working in the project area
to excessive noise levels?

DISCUSSION
Noise is typically defined as unwanted sound. In any one location, the noise level will vary over time, from the lowest background or ambient noise level to temporary increases caused by traffic or other sources.

State and federal standards have been established as guidelines for determining the compatibility of a particular use with its noise environment. The City of Willits relies principally on standards in its Noise Element of the City of Willits General Plan (1992), City Code (2021), the Development Element of the County of Mendocino General Plan (2020), the County of Mendocino Zoning Ordinance (1991), other County ordinances, and the Mendocino County Airport Comprehensive Land Use Plan (ACLUP, 1996) to evaluate noise-related impacts of development, depending on the location of proposed development.

APN: 108-040-18 is undeveloped, while Quail Meadows was previously a RV park which is now abandoned.

Existing noise sources near the Site include local traffic on N Main Street to the west, activities at Willits High School to the south, and operations at the existing lumber yard to the south.

An Environmental Noise Assessment, dated March 11, 2024, was prepared by Bollard Acoustical Consultants, Inc. (BAC) to quantify the existing noise environment at the Site, identify potential noise impacts at existing nearby sensitive receptors resulting from the Project, and to develop appropriate noise mitigation measures where impacts are identified (Appendix J). The Environmental Noise Assessment concluded that existing ambient noise at the existing log yard and Site ranges from 52 A-weighted decibels (dBA) to 67 dBA, with daytime maximum noise levels ranging from 69 dBA to 77 dBA, and that the baseline vibration environment at sensitive receptors in the immediate vicinity of the Site is considered to be negligible. Noise measurements were taken in accordance with the performance standards in Chapter 17.50 – Performance Standards of the City Code (2021).

Sensitive noise receptors are generally defined as locations where people reside or where the presence of unwanted sound or vibration could adversely affect the primary intended use of the land. Places where people live, sleep, recreate, worship, and study are generally considered to be sensitive to noise because intrusive noise and/or vibration can be disruptive to these activities. According to the Environmental Noise Assessment, sensitive noise receptors in the general vicinity of the Site include nearby residential uses to the west and Willits High School to the south. The locations of nearby sensitive noise receptors are shown on Figure 4 (Noise Measurement and Sensitive Receptor Locations) of the Environmental Noise Assessment.

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
The Environmental Noise Assessment compared noise impacts of the Project to a graduated scale for use in the assessment of project-related noise level increases developed by the Federal Interagency Commission on Noise (FICON). The FICON standards are considered conservative relative to thresholds used by other agencies in California. According to the FICON standards, an increase in 1.5 dB or more in areas with an existing ambient noise level of 65 dB or more would be considered significant. Additionally, pursuant to Policy

4.210 of the Willits General Plan (1992), the City seeks to maintain ambient noise levels of 55 dBA Community Noise Equivalent Level (CNEL) in existing residential areas, and pursuant to Policy 4.230, all sensitive land uses in areas with ambient noise levels in excess of 60 dBA shall require acceptable mitigation of noise impacts as a condition of approval.

Construction of the proposed Project would generate short-term noise from excavation, grading, drilling, earth movement, and vehicles traveling to and from the Site. Upon completion of construction, Project operations would generate noise in the form of log and lumber trucks transporting logs to and from the Site, log remanufacturing, and site maintenance. As the proposed Project is an extension of the existing log yard, noise levels are anticipated to be consistent with the existing log yard.

Operation of a typical industrial facility would be subject to Code Chapter 17.50 – Performance Standards.

Pursuant to Code Section 17.50.040 – Locations where determinations are made for enforcement of performance standards (1982), compliance with performance standards would generally be enforced within five hundred (500) feet of the Project Area. Operations would be anticipated to generally occur between 7:00am and 7:00pm up to six (6) days per week. Typical operational activities would be anticipated to include employee trips to the typical industrial facility, operation of heavy equipment within and outside of structures, heavy truck traffic to/from the facility for materials transfers, and use of machinery within structures. The noise levels generated by other typical industrial facilities that may occur at the Site are unknown at this time but would have the potential to exceed noise generated by the Project. Noise generating-uses would be subject to the Noise Policies and Implementation Measures found in Volume I of the Willits General Plan 2020 (1992) and Code Chapter 17.50 – Performance Standards, which provides performance standard regulations that specify noise limits, distances for measurement of noise and vibration levels, and parameters for understanding the type, location, and character of noise and vibration sources. The City would evaluate future typical industrial uses for conformance with existing policies and regulations.

XIII. a-b) Implementation of the proposed Project would not be expected to generate noise in excess of what is common for such improvements nor would the Project result in excessive ground borne vibration or ground borne noise levels. During construction, temporary noise would be anticipated as a result of utilizing construction equipment for excavation, grading, drilling, earth movement, and vehicles traveling to and from the Site. However, these noise impacts would be temporary in nature, and Mitigation Measure NOI-1 would be incorporated and implemented throughout construction, such as limiting construction to between the hours of 7:00 a.m. and 7:00 p.m. Monday through Saturday, or as approved by the City, using quiet models of air compressors and other stationary noise sources where technology exists, and use of mufflers on all internal combustion engine-driven equipment. In addition, with the exception of minor nearby vibrations created from standard heavy equipment, there are no elements of the proposed Project that would create permanent ground borne vibrations or noise levels.

Once construction is complete, operational noise generated by the Project would include log and lumber trucks transporting logs to and from the site, log remanufacturing, and site maintenance. BAC conducted noise level measurements of logging truck loading operations at the existing log yard, concluding a maximum noise level of 75 dBA and an average noise level of 62 dBA at a reference distance of 100 feet from the loading operations. BAC utilized industry standard sound propagation algorithms to conclude that

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
the noise level at nearby sensitive noise receptors during loading operations would range from 32 dB to 50 dB day-night average sound level (DNL), well below the 55 dB to 60 dB range considered acceptable for residential development, pursuant to Policies 4.210 and 4.230 of the Willits General Plan (1992). The noise generated by the truck unloading operation is comparable to the noise generation of the truck loading operation, as the same equipment is utilized for the same duration of time. As the proposed Project is an extension of the existing log yard, noise levels are anticipated to be consistent with the existing log yard. BAC also predicts the noise level increase generated by the Project at the nearest sensitive receptor to range from 0.0 to 0.7 dBA, which is well below the FICON’s threshold of significance of 1.5 dBA. Furthermore, as discussed above, BAC observed no significant sources of vibration and found that vibration levels at off-site locations were evaluated as being imperceptible during loading operations. Therefore, noise levels and vibration generated by the Project would be consistent with surrounding uses and local noise regulations, and a less than significant impact would occur.

Construction of other typical industrial facilities would also be required to comply with Mitigation Measure NOI-1 to ensure noise generated during construction would not create a substantial temporary increase in ambient noise levels. Noise generated by operation of other typical industrial facilities that may occur at the Site are unknown at this time but would have the potential to exceed noise generated by the Project. Noise generating-uses would be subject to the Noise Policies and Implementation Measures found in Volume I of the Willits General Plan 2020 (1992) and Code Chapter 17.50 – Performance Standards, which provides performance standard regulations that specify noise limits, distances for measurement of noise and vibration levels, and parameters for understanding the type, location, and character of noise and vibration sources.

If proposed in the future, the City would evaluate development of a typical industrial use for conformance with existing policies and regulations. Mitigation Measure NOI-2 would require that a noise assessment be conducted for other future industrial uses at the Site to ensure noise levels would not generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the Site in excess of standards established in the Willits General Plan (1992), City Code (2021), and other applicable noise standards.

XIII. c) The nearest airport to the Site is the Ells Field (Willits Municipal Airport), located approximately 1.88 miles northwest of the Site at its closest point. According to the ACLUP, the Site is not located within the compatibility boundary of the Ells Field (Willits Municipal Airport) (County of Mendocino, 1996). As such, a less than significant impact would occur.

MITIGATION MEASURES
NOI-1: To reduce the possibility of the construction noise becoming an annoyance to existing residences near the Site, exterior construction activity shall be confined to between the hours of 7:00 a.m. and 7:00 p.m.

Monday through Saturday, or as approved by the City. Additionally, construction activities shall utilize quiet models of air compressors and other stationary noise sources where technology exists and use mufflers on all internal combustion engine-driven equipment.

NOI-2: To ensure future typical industrial facilities that would be allowed under the land use and zoning designations of M-G and MH do not generate noise in excess of standards established in the Willits General Plan (1992), City Code (2021), and other applicable noise standards, a noise assessment shall be conducted to analyze noise that may be generated by the project. If the noise assessment concludes that noise generated by the project would exceed standards established in the Willits General Plan (1992), City Code (2021), and other applicable noise standards, abatement measures shall be incorporated into the project design to reduce noise to below these standards.

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025

FINDINGS
The proposed Project and other typical industrial facilities would have a Less Than Significant Impact With Mitigation Incorporated on Noise.

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
XIV. POPULATION AND HOUSING. Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Induce substantial unplanned population growth in
an area, either directly (e.g., by proposing new homes
and/or businesses) or indirectly (e.g., through
extension of roads or other infrastructure)?
b) Displace substantial numbers of existing people or
housing, necessitating the construction of
replacement housing elsewhere?

DISCUSSION
According to the 2019-2027 Housing Element of the City of Willits General Plan (2019), the population of Willits increased by more than 4 percent from 2010 to 2018, from 4,888 to 5,128 persons; however, the population growth is expected to slow over the next five years, decreasing to 2 percent county-wide. In 2016, Willits had 2,120 total housing units, 2,028 of which were occupied, with an average household size of approximately

2.52 persons in 2018. The City of Willits General Plan (1992) forecasted an ultimate build-out population in Willits of approximately 7,500 residents by 2020, which would result in an estimated 33 percent increase in water consumption and would require careful monitoring of the available water services due to the limited capacity of and impact of drought on the City’s surface water supply.

XIV.a) The Project would not induce substantial population growth in Willits, as substantial population growth, which has not yet been realized, was projected in the City of Willits General Plan (1992). The proposed Project is an extension of the existing log yard. Employees needed to support the proposed and existing log yard would include existing four (4) full-time staff, one (1) new full-time Log Procurement Manager, and one (1) seasonal employee generally from April 1 to November 30 (summer period). As the Project would only require one (1) new full-time employee and one (1) new seasonal employee, who would likely be hired locally, the Project would not induce substantial population growth. A less than significant impact would occur.

Other typical industrial facilities would not induce substantial population growth. As single-family residences, supportive housing, and transitional housing are conditionally permitted uses in both the current zoning designations of C1 and C2 and the proposed zoning designation of MH, it is not anticipated that the GPA and Rezone would induce population growth by allowing new residential development. Typical industrial facilities may require additional employees at the Site. However, as employees would also be anticipated for typical facilities allowed under the current zoning designations of C1 and C2, and as employees could be hired locally, the GPA and Rezone would not be anticipated to induce a substantial unplanned population growth. A less than significant impact would occur.

XIX.b) As discussed above, the Project and other typical industrial facilities would not be anticipated to induce substantial population growth. Additionally, no existing housing units would be removed under the Project or other typical industrial facilities, as no housing units are located at the Site. As such, neither the Project nor other typical industrial facilities would displace any existing housing or residents. A less than significant impact would occur.

MITIGATION MEASURES
No mitigation required.

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025

FINDINGS
The proposed Project and other typical industrial facilities would have a Less Than Significant Impact on Population and Housing.

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
XV. PUBLIC SERVICES. Would the project result in
substantial adverse physical impacts associated
with the provision of new or physically altered
governmental facilities, need for new or
physically altered governmental facilities, the
construction of which could cause significant
environmental impacts, in order to maintain
acceptable service ratios, response times or
other performance objectives for any of the
public services:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Fire protection?
b) Police protection?
c) Schools?
d) Parks?
e) Other public facilities?

DISCUSSION
As previously discussed, the Site has a land use designation of C-G, and Quail Meadows and APN: 108-040- 18 have zoning designations of C2 and C1, respectively. The proposed Project involves a GPA and Rezone to change the existing land use and zoning designations of the Site to M-G and MH, respectively, similar to the existing log yard (see Figures 3 and 4). However, the Applicant requests a BLA to retain an approximately

2.2-acre portion of APN: 108-040-18 as C-G and C1 land use and zoning designations, respectively, and would not be included in the proposed GPA and Rezone. Upon completion of the Project, one (1) new fulltime employee and one new (1) seasonal employee would be required to support the proposed improvements and expansion of the Site.

Fire protection services at the Site are provided by the Little Lake Fire District. The nearest fire station to the Site is located at 74 E. Commercial Street, Willits, approximately 0.5 mile south of the Site (Little Lake Fire District, 2023).

Police protection services are provided by the Willits Police Department. The police station is located at 125 E. Commercial Street #150, Willits, approximately 0.5 miles south of the Site [City of Willits, No Date (c)].

The City’s public school system is made up of Willits Unified School District, which provides six (6) public schools including three (3) elementary, one middle, and two high schools (Willits Unified School District, 2023). The nearest school to the Site is Willits High School, located south of the existing log yard. Willits High School athletic facilities are located approximately 600 feet south of the Site, and classrooms are located approximately 950 feet south of the Site.

A description of parks and recreational facilities in the general vicinity of the Site is in Section XVI (Recreation), below.

XV.a) The Project would have the potential to increase fire protection above current levels at the Site.

However, all development would be sited within the area that is currently served by the Little Lake Fire District.

The proposed Project would be equipped with a fire suppression system in compliance with the Little Lake Fire District as described in their letter dated March 17, 2023 (Appendix K). The Project would be required to comply with all requirements of the Little Lake Fire District, including a maximum log deck size of 300 feet by 500 feet, a 100-foot separation from other log decks and exposures, and maintaining vehicle access to all

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
log decks, ponds, and on-site hydrants. The maximum deck height has been expanded from 20 feet to 30 feet with approval from the Fire Marshall and incorporation of sprinkled log decks. Furthermore, pursuant to Mitigation Measure HAZ-1, an EAP would be prepared prior to operation of the expanded log yard, which would include fire prevention, mitigation, and response strategies. The EAP would include, but not be limited to access requirements, evacuation routes and procedures, employee trainings, deck orientation maps, adequate water supply, on-site firefighting equipment, and fire prevention and mitigation. Through compliance with requirements from the Little Lake Fire District and the incorporation of Mitigation Measure HAZ-1, a less than significant impact would occur.

Other typical industrial facilities would also have the potential to increase fire protection above current levels at the Site. However, building permit applications for a typical industrial facility would be subject to review by the Little Lake Fire District for compliance with the current version of the CFC at the time of building permit application submittal, and conditions would be implemented to ensure a project does not significantly increase fire protection services at the Site. Typical conditions would be anticipated to be related to maintaining site access and circulation for emergency equipment, emergency water supply, property signage, flammable materials storage, and other conditions as required by the Fire Marshal in accordance with the current CFC at the time a project is proposed. Additionally, Mitigation Measure HAZ-1 would require preparation of an EAP, which would include fire prevention, mitigation, and response strategies. With mitigation incorporated, a less than significant impact would occur.

XV.b) There are no portions of either the proposed Project or other typical industrial facilities that would require additional police protection. As discussed in Section XIV (Population and Housing), neither the Project nor other typical industrial facilities would be anticipated to induce unplanned population growth. Therefore, there would be no impact on police protection.

XV.c) As discussed in Section XIV (Population and Housing), neither the Project nor other typical industrial facilities would be anticipated to induce unplanned population growth. Therefore, there are no portions of either the proposed Project or other typical industrial facilities that would require construction of a new school.

Willits High School is located immediately south of the existing log yard. Willits High School athletic facilities are located approximately 600 feet south of the Site, and classrooms are located approximately 950 feet south of the Site. However, Willits High School would not be impacted by the Project or other typical industrial facilities, as no unmitigated significant adverse impacts were identified in this IS, including but not limited to impacts related to air quality, noise, and hazards and hazardous materials. With Mitigation Measures HAZ-1, NOI-1, and NOI-2, there would be a less than significant impact on Willits High School.

XV.d-e) As discussed in Section XIV (Population and Housing), no residential units would be constructed, nor is the population expected to substantially increase as a result of the proposed Project or other typical industrial facilities. As the proposed Project and other typical industrial facilities would not substantially increase the population, it would not create a need for new or physically altered park facilities or other public facilities. Therefore, no adverse physical impacts would be associated with the construction of such facilities.

No impact would occur.

MITIGATION MEASURES
Refer to Mitigation Measure HAZ-1 under Section IX (Hazards and Hazardous Materials) and Mitigation Measures NOI- and NOI-2 under Section XIII (Noise), above.

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025

FINDINGS
The proposed Project and other typical industrial facilities would have a Less Than Significant Impact With Mitigation Incorporated on Public Services.

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
XVI. RECREATION. Would the project: Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Increase the use of existing neighborhood and
regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
b) Include recreational facilities or require the
construction or expansion of recreational facilities
which might have an adverse physical effect on the
environment?

DISCUSSION
The Site is located in the vicinity (within 8 miles) of the following neighborhood and regional parks and recreational facilities:
• Recreation Grove, located approximately 0.9 miles southwest of the Site; • Bud Snider City Park, located approximately 0.9 miles southwest of the Site; • Willits Rodeo Grounds, located approximately 1 miles south of the Site; • Frank Grasse Dog Park and Willits Skate Park, located approximately 1.1 miles south of the Site; • Highway 20 Park, located approximately 1.2 miles southwest of the Site; • Babcock Park, located approximately 1.3 miles southwest of the Site; • Willits Municipal Swimming Pool, located approximately 2.6 miles west of the Site; • Ohl Redwood Grove Park, located approximately 2.6 miles west of the Site; • Little Darby Environmental Education Area and Nature Trail, located approximately 7.1 miles east of the Site; and
• Haehl Creek Trailhead, located approximately 2.5 miles southeast of the Site.

XVI. a-b) No residential units would be constructed, nor is the population expected to substantially increase, as a result of the proposed Project or other typical industrial facilities. There would not be an increase in the usage of or demand for neighborhood and regional parks or other recreational facilities. Therefore, neither the proposed Project nor other typical industrial facilities would result in the physical deterioration of parks or facilities, nor would they require the construction of new park or recreational facilities. No impact would occur.

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed Project and other typical industrial facilities would have No Impact on Recreation.

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
XVII. TRANSPORTATION. Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Conflict with a program, plan, ordinance or policy
addressing the circulation system, including transit,
roadway, bicycle and pedestrian facilities?
b) Conflict or be inconsistent with CEQA Guidelines
section 15064.3, subdivision (b)?
c) Substantially increase hazards due to a geometric
design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm
equipment)?
d) Result in inadequate emergency access?

DISCUSSION
On September 27, 2013, Governor Jerry Brown signed Senate Bill (SB) 743 into law, initiating an update to the CEQA Guidelines to change how lead agencies evaluate transportation impacts under CEQA, with the goal to better measure the actual transportation-related environmental impacts of a given project. Traditionally, transportation impacts had been evaluated by using Level of Service (LOS) analysis. Starting July 1, 2020, lead agencies are required to analyze the transportation impacts of new projects using Vehicle Miles Traveled (VMT), instead of LOS. According to the SB 743 Frequently Asked Questions provided by the Governor’s Office of Planning and Research (OPR), VMT measures how much actual auto travel (additional miles driven) a proposed project would create on California roads. If the project adds excessive car travel onto the roads, the project may cause a significant transportation impact. Vehicle Miles Traveled (VMT) analysis is intended to promote the state’s goals of reducing greenhouse gas emissions and traffic-related air pollution, promoting the development of a multimodal transportation system, and providing clean, efficient access to destinations (OPR, 2020).

A Focused Traffic Study was prepared by W-Trans on November 29, 2023 (Appendix E), to assess the potential transportation related impacts associated with the proposed Project and other typical industrial facilities. Per the Focused Traffic Study, the study area consists of N Main Street, which generally runs north-south through the center of Willits. Along the Site frontage, N Main Street has a two-way left-turn lane, in addition to two (2) 11-foot travel lanes, and a posted speed limit of 35 miles per hour (mph) (W-Trans, 2023).

The Site is currently accessed from N Main Street via a paved driveway at the southwest corner of Quail Meadows. An additional unimproved driveway is located at the northwest corner of the Site. The existing log yard is accessed via Casteel Lane. The Applicant proposes to utilize both the Quail Meadows entrance and the Casteel Lane entrance at the existing log yard for accessing the Site. There is an existing two-way leftturn lane on N Main Street that is utilized for inbound traffic inbound at Casteel Lane. The northerly driveway on the Quail Meadow site is not served by this two-way left-turn (W-Trans, 2023). An additional unimproved driveway is located at the northwest corner of the Site. This driveway is intended for light administrative use only and not for industrial truck or equipment traffic. The Applicant seeks to extend this driveway southeast to connect to internal access roads as shown on Figure 5: Site Plan. The northwest driveway also serves a northern access road that is utilized by Caltrans to access off-site properties to the east. No changes are proposed to Caltrans’ ongoing maintenance activities to the northern access road. As noted above, the central portion of the Site contains various internal gravel access roads utilized for the previous development.

These gravel access roads would be maintained, upgraded, and/or constructed, where needed, to facilitate on-site circulation and to connect the existing log yard and the Site.

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
As observed at the existing log yard, the majority of log deliveries occur during the summer period, five (5) to six (6) days per week, generally between the hours of 6:00am and 5:00pm, with occasional peak delivery times from 5:30am to 7:00pm. At times during the summer and fall months, the operators work until 5:30pm or 6:00pm to clean up the yard after the trucks have stopped coming in. During this period, logs are delivered to the Site on approximately 50 to 60 incoming log trucks per day, up to a maximum of 65 to 70 incoming trucks per day, on rare occasions. During this summer period, logs are transported from the Site on approximately 15 to 20 outbound lumber trucks per day, up to approximately 25 outbound lumber trucks per day, on rare occasions. Hours of operation between December 1 and March 30 (winter period) are generally from 7:00am to 4:00pm, up to five (5) days per week, with occasional needs to operate between 6:00am and 5:00pm to accommodate lumber truck scheduling for backhauls and log deliveries during mild weather windows in spring. Incoming log deliveries during the winter period are minimal, up to approximately 15 incoming log trucks per day, in isolated circumstances. Log deliveries during the winter period are dependent on weather at the source of logs and harvest permit and wet season logging restrictions. During this winter period, logs are transported from the Site on approximately 25 to 30 outbound lumber trucks per day.

Additionally, bark hauling occurs intermittently throughout the year at rates of two (2) to five (5) loads per week. Trips associated with bark hauling are limited to normal operating hours described above. Bark loads are not significant enough to increase the daily truck averages over the incoming and outgoing load forecasts described. These forecasted truck trips and operating hours are consistent with the existing operation. With implementation of the proposed project, it is anticipated that truck trips per day to and from the expanded log yard would average towards the upper end of the ranges provided with more consistency. The existing log yard experiences truck trips within these ranges with less consistency. The majority of log trucks would access the Site from the north, via the Highway 101 offramp directly north of the Site; however, log trucks traveling from the coast via Highway 20, would access the Site from the south, via N Main Street.

According to the Focused Traffic Study (Appendix E), the existing log yard receives an average of 55 truckloads of logs daily for six (6) months of the year and approximately 10 loads the other six (6) months, for an annual average of 33 trucks entering the site daily. Given the nine-hour workday, a maximum of five (5) trucks during a single hour would be expected. As trucks require more space on the roadway and more time to make movements, the Focused Traffic Study assumed a vehicle equivalency of three passenger vehicles per truck, translating the five (5) inbound trucks to 15 inbound vehicle movements. An additional 2 trips were assumed for employees or other vehicles for a total of 17 inbound trips in an hour. Assuming that trucks would come from US 101, it is likely that the drivers would enter via the first driveway they encounter at Quail Meadows. Of the 17 total inbound trips, 15 were assumed to occur at APN: 108-040-11 (Quail Meadow) driveway. Based on counts at N Main Street and the Project’s trip generation, the Focused Traffic Study determined that a left-turn pocket is not warranted (W-Trans, 2023).

The Focused Traffic Study determined that for the posted speed limit of 35 mph, 250 feet of sight distance is needed. From the Quail Meadows driveway, sight lines extend more than 300 feet in both directions. At the existing driveway at Casteel Lane, there are clear sight lines for more than 500 feet in either direction.

Therefore, sight lines are adequate at both driveways (W-Trans, 2023).

The Project is intended to increase operational efficiencies for the Applicant by reducing the number of truck trips between Eureka and Willits. The Project is not expected to increase trips on peak days (W-Trans, 2023).

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
The Focused Traffic Study used standard trip generation rates for various uses to analyze potential trip generation of other typical industrial facilities. Table 1 of the Focused Traffic Study (Appendix E) shows that trip generation for light industrial uses are substantially lower than those for typical commercial uses, such as office, retail, or service uses (W-Trans, 2023).

XVII.a) The proposed Project would not conflict with a plan, ordinance, or policy addressing the circulation system, including transit, roadways, bicycle lanes, and pedestrian paths. It is expected that Project construction would result in a slight increase in traffic to and from the Site, as construction workers arrive and leave the Site at the beginning and end of the day, in addition to minor interruption of traffic on adjacent streets, when heavy equipment necessary for Project construction is brought to and removed from the Site.

However, once construction is complete, these temporary workers would no longer be required at the Site.

Construction of other typical industrial facilities would be anticipated to be similar, as construction would be temporary.

Upon Project completion, daily operations would be consistent with the existing operations of the Casteel Lane log yard, which would include log and lumber trucks transporting logs to and from the Site, log bucking and remanufacturing, loading bark and other byproducts, lumber trailer staging, and site maintenance, including minor grading, resurfacing, and watering. One (1) new full-time employee and one (1) new seasonal employee would be required for Project operation, thereby resulting in a slight increase in traffic trips to and from the Site as employees arrive and leave the Site each day. However, the Focused Traffic Study concludes that the proposed Project would not be expected to generate a substantial number of new trips for employees or trucks. The proposed Project is not expected to significantly impact the capacity of the street system, LOS standards established by the City, or the overall effectiveness of the circulation system, nor substantially impact alternative transportation facilities, such as transit, bicycle, or pedestrian facilities, as the Project is an expansion of an existing operation and a substantial increase in traffic trips or use of alternative transportation facilities is not anticipated. A less than significant impact would occur.

Operation of other typical industrial facilities would not be anticipated to conflict with a plan, ordinance, or policy addressing the circulation system. The Focused Traffic Study used standard trip generation rates for various uses to analyze potential trip generation of other typical industrial facilities. Table 1 of the Focused Traffic Study (Appendix E) shows that trip generation for light industrial uses are substantially lower than those for typical commercial uses, such as office, retail, or service uses (W-Trans, 2023). The proposed Rezone is for MH, heavy industrial, rather than light industrial. However, commercial uses tend to generate a higher number of trips, as commercial uses are often utilized by the public. Light and heavy industrial uses are not utilized by the public to the same level as commercial uses. Based on a review of the uses permitted in C1, C2, and MH in Table 2 of this IS, it appears that uses permitted in C1 and C2 tend to involve more interaction with the public than uses permitted in MH. Based on the substantially lower trip generation of light industrial uses than typical commercial uses and the nature of public utilization of commercial uses, it is reasonable to anticipate that other typical industrial facilities permitted by the GPA and Rezone would result in lower trip generation than would be anticipated with the existing zoning designation of C1 and C2. A less than significant impact is anticipated.

XVII.b) The proposed Project would not conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b), which states:
“(1) Land Use Projects. Vehicle miles traveled exceeding an applicable threshold of significance may indicate a significant impact. Generally, projects within one-half mile of either an existing major transit stop or a stop along an existing high quality transit corridor should be presumed to cause a less than significant transportation impact. Projects that decrease vehicle miles traveled

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
in the project area compared to existing conditions should be considered to have a less than significant transportation impact.
(2) Transportation Projects. Transportation projects that reduce, or have no impact on, vehicle miles traveled should be presumed to cause a less than significant transportation impact. For roadway capacity projects, agencies have discretion to determine the appropriate measure of transportation impact consistent with CEQA and other applicable requirements. To the extent that such impacts have already been adequately addressed at a programmatic level, a lead agency may tier from that analysis as provided in Section 15152.” The Project is a land use project and is not considered a transportation project under CEQA. The Site is approximately 2,600 feet (0.49 miles) from the nearest transit stop to the south. According to CEQA Guidelines Section15064.3, subdivision (b), a land use project at the Site would not be presumed to cause a less than significant transportation impact.

As of the date of this IS, the City of Willits has not established a threshold with regard to VMT impact significance consistent with CEQA Guidelines Section 15064.3, subdivision (b). However, as noted in the Focused Traffic Study, prepared by W-Trans on November 29, 2023, the Mendocino Council of Governments (MCOG) adopted Senate Bill 743 Vehicle Miles Traveled Regional Baseline Study (Regional Baseline Study) in June 2020, which includes a recommended a methodology and thresholds for assessing VMT impacts within Mendocino County. As such, the MCOG methodology was utilized to assess the potential VMT related impacts of the proposed Project. Through this methodology, W-Trans determined that VMT analysis was not relevant as the Regional Baseline Study adopted by MCOG does not provide VMT thresholds associated with heavy-duty trucks (W-Trans, 2023).

Although specific VMT thresholds are not provided for heavy-duty trucks, the purpose of the Project is to increase operational efficiencies for the Applicant, which in turn is expected to reduce the number of truck trips between Eureka and Willits. This would be expected to result in a reduction in GHG emissions, which supports the overall intent of SB 743 (W-Trans, 2023). As a result, the Project would result in a less than significant impact.

Operation of other typical industrial facilities would not be anticipated to increase traffic beyond what would be allowed by the existing zoning of C1 and C2. The Focused Traffic Study used standard trip generation rates for various uses to analyze potential trip generation of other typical industrial facilities. Table 1 of the Focused Traffic Study (Appendix E) shows that trip generation for light industrial uses are substantially lower than those for typical commercial uses, such as office, retail, or service uses (W-Trans, 2023). The proposed Rezone is for MH, heavy industrial, rather than light industrial. However, commercial uses tend to generate a higher number of trips, as commercial uses are often utilized by the public. Light and heavy industrial uses are not utilized by the public to the same level as commercial uses. Based on a review of the uses permitted in C1, C2, and MH in Table 2 of this IS, it appears that uses permitted in C1 and C2 tend to involve more interaction with the public than uses permitted in MH. Based on the substantially lower trip generation of light industrial uses than typical commercial uses and the nature of public utilization of commercial uses, it is reasonable to anticipate that other typical industrial facilities permitted by the GPA and Rezone would result in lower trip generation than would be anticipated with the existing zoning designation of C1 and C2. A less than significant impact is anticipated.

XVII.c-d) The proposed Project is not anticipated to substantially increase hazards due to design features or incompatible uses or result in inadequate emergency access. As noted in the Focused Traffic Study, both

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
existing driveways have adequate sight distance. For the posted speed limit of 35 mph, 250 feet of sight distance is needed. From the Quail Meadows driveway, sight lines extend more than 300 feet in both directions. At the existing Casteel Lane driveway, there are clear sight lines for more than 500 feet in either direction. Additionally, the Focused Traffic Study concluded that no additional improvements, specifically a left-turn pocket at the Quail Meadow driveway on N Main Street, would be necessary. Furthermore, the Project’s access and circulation were designed to account for feedback received from Caltrans. The proposed Project would comply with all requirements of the Little Lake Fire District, including a maximum log deck size of 300 feet by 500 feet, a 100-foot separation from other log decks and exposures, and maintaining vehicle access to all log decks, ponds, and on-site hydrants. Additionally, the maximum deck height has been expanded from 20 feet to 30 feet with approval from the Fire Marshall and incorporation of sprinkled log decks. The Site has been designed to accommodate large logging trucks, and, as a result, it is anticipated that all types of vehicles, including emergency vehicles, would be able to adequately navigate the Site (WTrans, 2023). As such, a less than significant impact would occur.

Other typical industrial facilities would not be anticipated to substantially increase hazards due to design features or incompatible uses or result in inadequate emergency access. Building permit applications for a typical industrial facility would be subject to review by the Little Lake Fire District for compliance with the current version of the CFC in place at the time of building permit application submittal. Typical conditions would be anticipated to be related to maintaining site access and circulation for emergency equipment, emergency water supply, property signage, flammable materials storage, and other conditions as required by the Fire Marshal in accordance with the current CFC at the time a project is proposed. Compliance with conditions required by the Fire Marshall of the Little Lake Fire District would ensure that future uses of the Site are designed so that hazards at the Site are not substantially increased and so that the Site has adequate emergency access. A less than significant impact would occur.

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed Project and other typical industrial facilities would have a Less Than Significant Impact on Transportation.

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
XVIII. TRIBAL CULTURAL RESOURCES. Would the
project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Would the project cause a substantial adverse
change in the significance of a tribal cultural resource, defined in Public Resources Code §21074 as either a
site, feature, place, cultural landscape that is
geographically defined in terms of the size and scope
of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that
is:
i) Listed or eligible for listing in the California
Register of Historical Resources, or in a local
register of historical resources as defined in
Public Resources Code §5020.1(k)?
ii) A resource determined by the lead agency,
in its discretion and supported by substantial
evidence, to be significant pursuant to criteria
set forth in subdivision (c) of Public Resources
Code §5024.1? In applying the criteria set
forth in subdivision (c) of Public Resources
Code §5024.1, the lead agency shall consider
the significance of the resource to a
California Native American tribe.

DISCUSSION
According to Development Element of the Mendocino County General Plan (2020), ten (10) Native American tribes historically had territory in what is now Mendocino County. Native American tribes known to inhabit Mendocino County concentrated mainly along the coast and along major rivers and streams, while some tribes seasonally occupied mountainous areas and redwood groves. The entire southern third of Mendocino County was the home of groups of Central Pomo. To the north of the Central Pomo groups were the Northern Pomo, who controlled a strip of land extending from the coast to Clear Lake. The Coast Yuki claimed a portion of the coast from Fort Bragg north to an area slightly north of Rockport. They were linguistically related to a small group, called the Huchnom, living along the South Eel River north of Potter Valley. Both of these smaller groups were related to the Yuki, who were centered in Round Valley. At the far northern end of Mendocino County, several groups extended south from Humboldt County. Branscomb, Laytonville, and Cummings bounded the territory of the Cahto. The North Fork Wailaki was almost entirely in Mendocino County, along the North Fork of the Eel River. Other groups in this area included the Shelter Cove Sinkyone, the Eel River, and the Pitch Wailaki (County of Mendocino, 2020). The first permanent non-native settlers came to Mendocino County in the middle of the 16th century, exploring and establishing small outposts. It was almost 300 years before the first permanent non-Spanish settlements in Mendocino County were established in April of 1852 on the coast north of Big River. Settlement in the vicinity of the City began in the mid-1880s (City of Willits, 1992, pg. III-27). As European-American settlement expanded in Mendocino County, most of the tribes known to inhabit the land were restricted to reservations and rancherias. During the 19th century, other tribes from the interior of California were forced to settle on the Round Valley Reservation in the northeastern portion of Mendocino County (County of Mendocino, 2020).

Outreach and correspondence with the NAHC occurred during preparation of the August 2020 Cultural Study. In July 2020, a SLF Search was requested from the NAHC. On July 3, 2020, the NAHC provided a response that indicated the results of the SLF Search were negative. The NAHC additionally provided a list of

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
Native American tribes that may have knowledge of cultural resources in the Project area. On December 14, 2022, in compliance with Assembly Bill (AB) 52 and Senate Bill (SB) 18, the City of Willits sent consultation letters to the Tribal Historic Preservation Officer (THPO) or appropriate representative for each of the following 15 Native American tribes: Coyote Valley Band or Pomo Indians, Guidiville Indian Rancheria, Hopland Band of Pomo Indians, Cahto Tribe, Manchester Band of Pomo Indians of the Manchester Rancheria, Middletown Rancheria of Pomo Indians, Noyo River Indian Community, Pinoleville Pomo Nation, Potter Valley Tribe, Redwood Valley or Little River Band of Pomo Indians, Robinson Rancheria of Pomo Indians, Round Valley Reservation/Covelo Indian Community, Scotts Valley Band of Pomo, Sherwood Valley Rancheria of Pomo, Yokayo Tribe, and Torres Martinez Desert Cahuilla Indians. Two Native American tribes, the Manchester Band of Pomo Indians of the Manchester Rancheria and the Sherwood Valley Rancheria of Pomo, responded to request additional information. No Native American tribes responded with concerns regarding the proposed Project. Copies of the NWIC response letter and the NAHC Native American Contacts List are included in Appendix F.
a.i-ii) As discussed in Section V (Cultural Resources), above, no historical resources are identified at or near the Site, per Figure 10-1 of the City of Willits General Plan (1992), no responses were received from the Tribal consultation effort that expressed concerns regarding the proposed Project, and there are no known Tribal cultural resources at the Site. However, there is the possibility that a tribal cultural resource could be discovered inadvertently due to the ground-disturbing activities required during construction of the Project or other typical industrial facilities. The incorporation of Mitigation Measure CUL-1, which requires that the contractor of the Project or other typical industrial facilities implement standard protocol similar to Mendocino County’s “Discovery Clause” during construction, and Mitigation Measure CUL-2, which establishes protocol in the event that human remains are encountered on-site, would ensure that any currently unknown tribal cultural resources that are discovered during construction are not adversely impacted. With mitigation incorporated, a less than significant impact would occur.

MITIGATION MEASURES
Refer to Mitigation Measures CUL-1 through CUL-3 under Section V (Cultural Resources), above.

FINDINGS
The proposed Project and other typical industrial facilities would have a Less Than Significant Impact with Mitigation Incorporated on Tribal Cultural Resources.

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
XVIX. UTILITIES AND SERVICE SYSTEMS. Would the
project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or
stormwater drainage, electric power, natural gas, or
telecommunications facilities, the construction or
relocation of which could cause significant
environmental effects?
b) Have sufficient water supplies available to serve the project and reasonably foreseeable future
development during normal, dry, and multiple dry
years?
c) Result in a determination by the wastewater
treatment provider, which serves or may serve the
project that it has adequate capacity to serve the
project’s projected demand in addition to the
provider’s existing commitments?
d) Generate solid waste in excess of state or local
standards, or in excess of the capacity of local
infrastructure, or otherwise impair the attainment of
solid waste reduction goals?
e) Comply with federal, state, and local management
and reduction statutes and regulations related to solid waste?

DISCUSSION
The Site is comprised of two (2) parcels: Quail Meadows and APN: 108-040-18. While the Site is entirely privately-owned, the entirety of the Site is located within the City of Willits.

Water
The majority of water utilized for the Project would be from on-site wells, as the Applicant anticipates that the four (4) existing wells plus the up to three (3) proposed wells would be sufficient for meeting the needs of the current and expanded log yards, with the proposed ponds available for irrigation water storage and fire suppression needs. However, as noted above, the existing connection to the City water system would be maintained and/or upgraded, as needed, to serve as a back-up supply for irrigation needs, when necessary in the events of emergency well problems and/or mechanical failures during the dry months when water is needed on the log decks. A separate connection exists to serve fire suppression needs in the event of a fire emergency. The Applicant intends to have a self-sustaining water system through the use of on-site wells and wintertime collection and storage in the proposed ponds for use during the following summer. It is not anticipated that City water would be needed as an emergency backup water supply during the months of January through April and December when the need for log deck wetting is limited, and the ponds would likely contain water. For the months of May through November, up to approximately 90,000 gpd (peak usage) may be necessary as an emergency backup water supply. This estimate is based on the recorded highest usage of City water during an emergency at the existing log yard. A 10-day period of emergency water use is anticipated to be more than adequate to complete water system repairs or to allow for other unforeseen circumstances that would require the use of City water as a backup supply. Over a 10-day period, approximately 2.76 ac-ft (900,000 gallons) would be anticipated to be necessary. This estimate would allow for 10 days of makeup water to combat evaporation and four (4) water truck loads per day for dust

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
abatement. Water services for the Project are described in additional detail in Section X (Hydrology and Water Quality).

Wastewater
A sewage pumping station exists within close proximity to the office. Sewer lines run to the pumping station from the office and old infrastructure from the previous RV park. The sewage pumping station connects to the main line, which is serviced by the City of Willits. The City’s NPDES Permit Number CA0023060 states that the City of Willits Wastewater Treatment Facility has the capacity to serve current and future wastewater demand through 2025 (NCRWQCB, 2021).

Electric and Natural Gas
Electricity and natural gas connections currently exist on-site. The Applicant anticipates upgrading the existing power supply to meet operational needs. Potential typical industrial facility operators would coordinate with PG&E at the time a project is proposed if additional electricity or natural gas connections or supplies are needed.

Telecommunications
Telecommunications services would be obtained by the Applicant and future industrial facility operators, if needed.

Stormwater
Under the Project, post-construction stormwater would continue to infiltrate as the Project does not propose the introduction of impervious surfaces. However, stormwater would be collected in the two (2) ponds proposed at the Site for use as an emergency water supply and for irrigation needs.

While the City does not operate a municipal separate storm sewer system (MS4) that would otherwise be subject to the Municipal Storm Water Program administered by the SWRCB, including typical requirements for Low Impact Development (LID) feature in site design, compliance with the CGP would help to ensure post-construction stormwater flows for the Project and other typical industrial facilities are properly managed in accordance with the Clean Water Act. Furthermore, industrial facilities such as manufacturers, landfills, mining, steam generating electricity, hazardous waste facilities, transportation with vehicle maintenance, larger sewage and wastewater plants, recycling facilities, and oil and gas facilities would also be subject to coverage under the Statewide General Permit for Stormwater Discharges Associated with Industrial Activities, Order 2014-0057-DWQ (IGP), administered by the SWRCB.

Solid Waste
Waste generated by the Project and other typical industrial facilities would be hauled off-site to a licensed disposal facility or collected by the local waste hauling company, if needed.

XVIX.a) The proposed Project and other typical industrial facilities is not anticipated to require or result in the relocation or construction of new or expanded water services, wastewater treatment, stormwater drainage, electric power, natural gas, or telecommunications facilities that could cause significant environmental effects. Water would be supplied by existing wells, and water supply is expected to be adequate for the Project during normal years and drought years without substantially decreasing groundwater, as discussed in Section X (Hydrology and Water Quality). Water usage proposed under other typical industrial facilities is anticipated to be comparable to, and possibly less than, the Project due to the importance of water in the log yard for keeping logs wet during storage. Wastewater services for the Project would not need to be expanded, and potential wastewater improvements for a typical industrial facility would be subject to

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Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
grading and/or building permits through the City. Under the Project, stormwater would continue to infiltrate as the Project does not involve the introduction of impervious surfaces. The Project and other typical industrial facilities would be required to comply with the CGP, and other typical industrial facilities would be required to comply with the IGP. Waste generated by the Project and other typical industrial facilities would be hauled off-site to a licensed disposal facility or collected by the local waste hauling company, if needed, and solid waste generation would not be in excess of local infrastructure, as any generation of solid waste would be typical for industrial uses. Furthermore, while the Applicant would upgrade existing power supply and obtain telecommunication services as needed, this would not be anticipated to result in significant environmental effects. A less than significant impact would occur.

XVIX.b) As discussed in Section X (Hydrology and Water Quality), the proposed Project is anticipated to utilize approximately 41.5 ac-ft annually, primarily between the months May through November. Groundwater usage in the area is expected to be fairly low, as most water users in the area obtain water services through the City of Willits. Figure 3-6 of the LLVGWMP shows that well density is low in the area surrounding the Site, as there were only 5-10 wells located in the section of Figure 3-6 that includes the Site as of 2020. The LLVGMP found that the Basin recovers quickly from declines in groundwater levels and did not identify any overdraft issues in the Basin.

A Well Impact Report prepared by VESTRA Resources and dated October 5, 2023, determined that each of the three (3) proposed wells for the Project would have a drawdown of less than one foot at the nearest structure, nearest off-site well, and within a one-mile radius (Appendix I). Based on these results, the extraction of groundwater from the proposed wells is not likely to interfere with the production and function of existing nearby wells and are not likely to cause subsidence that would adversely impact or damage nearby infrastructure.

The majority of water utilized for the Project would be from on-site wells, as the Applicant anticipates that the four (4) existing wells plus the up to three (3) proposed wells would be sufficient for meeting the needs of the current and expanded log yards, with the proposed ponds available for irrigation water storage and fire suppression needs. However, as noted above, the existing connection to the City water system would be maintained and/or upgraded, as needed, to serve as a back-up supply for irrigation needs when necessary in the event of emergency well problems and/or mechanical failures. The Applicant intends have a selfsustaining water system through the use of on-site wells and wintertime collection and storage in the proposed ponds for use during the following summer. It is not anticipated that City water would be needed as an emergency backup water supply during the months of January through April and December when the need for log deck wetting is limited, and the ponds would most likely contain water. For the months of May through November, up to approximately 90,000 gpd (peak usage) may be necessary as an emergency backup water supply. This estimate is based on the recorded highest usage of City water during an emergency at the existing log yard. A 10-day period of emergency water use is anticipated to be more than adequate to complete water system repairs or to allow for other unforeseen circumstances that would require the use of City water as a backup supply. Over a 10-day period, approximately 2.76 ac-ft (900,000 gallons) would be anticipated to be necessary. This estimate would allow for 10 days of makeup water to combat evaporation and four (4) water truck loads per day for dust abatement. Water services for the Project are described in additional detail in Section X (Hydrology and Water Quality).

In a typical industrial facility, water sources and storage would be required for daily operation and emergency fire suppression. The water usage proposed under typical industrial is anticipated to be comparable to, and possibly less than, the Project due to the importance of water in the log yard for keeping

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
logs wet during storage. Details on the specific locations, capacities, and dimensions of the ponds and/or other water storage facilities would be subject to grading and/or building permits through the City.

As such, it is anticipated that there would be sufficient water supplies available to serve the Project and other typical industrial facilities during normal, dry, and multiple dry years. As such, a less than significant impact would occur.

XVIX.c) City of Willits Wastewater Treatment Facility has the capacity to serve current and future wastewater demand through 2025 (NCRWQCB, 2021). Due to the nature of the Project, the proposed Project would not require any expansion of wastewater services. Potential wastewater improvements for a typical industrial facility would be subject to grading and/or building permits through the City. A less than significant impact would occur.

XVIX.d-e) Construction and operation of the proposed Project and other typical industrial facilities is not expected to generate a significant amount of solid waste that would be in excess of local infrastructure. The generation of solid waste would be typical for industrial uses. Additionally, all solid waste generated during construction and operation would be disposed of in accordance with all federal, state, and local statutes and regulations. A less than significant impact would occur.

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed Project and other typical industrial facilities would have a Less Than Significant Impact on Utilities and Service Systems.

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
XX. WILDFIRE. If located in or near state responsibility areas or lands classified as very high fire hazard
severity zones, would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Impair an adopted emergency response plan or
emergency evacuation plan?
b) Due to slope, prevailing winds, and other factors,
exacerbate wildfire risks, and thereby expose project
occupants to, pollutant concentrations from a wildfire
or the uncontrolled spread of a wildfire?
c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency
water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
d) Expose people or structures to significant risks,
including downslope or downstream flooding or
landslides, as a result of runoff, post-fire slope
instability, or drainage challenges?

DISCUSSION
Mendocino County adopted several plans that include wildfire hazard management and mitigation including, but not limited to: Mendocino County Community Wildfire Protection Plan (2005), Emergency Operations Plan, and Multi-Jurisdictional Hazard Mitigation Plan (2021), in which the City is a participant. In addition, in October 2019, the City released a Public Review Draft of the 2019 Safety Element of the City of Willits General Plan to identify safety risks the City faces and develop goals, policies, and implementation programs to better address the issues. The 2020 Mendocino County Multi-Jurisdictional Hazard Mitigation Plan was approved by FEMA in February 2021. Based on information provided in the 2020 Multi-Jurisdictional Hazard Mitigation Plan, twenty-seven (27) wildfires occurred in Mendocino County between 2002 and 2018, some of which overlapped with neighboring counties, with each fire burning over 1,000 acres (2021).

As discussed under Section IX (Hazards and Hazardous Materials), above, both parcels are within the LRA.

According to the CAL FIRE LRA Fire Hazard Severity Zone Maps (2024), the majority of the Site is located within a “Moderate” fire hazard severity zone. The area to the west of the Site is within the State Responsibility Area (SRA) and is mapped as a “Moderate” fire hazard severity zone. The Site is within the service boundaries of the Little Lake Fire District, which provides fire protection and emergency medical services to the City of Willits.

The nearest fire station to the Site is located approximately 0.5 miles south of the Site, at 74 East Commercial Street in Willits.

Furthermore, as previously described under Section IX (Hazards and Hazardous Materials), in accordance with the 2019 CFC, the log decks at the existing log yard are a maximum of 300 feet by 500 feet (150,000 square feet). The maximum deck height has been expanded from 20 feet to 30 feet with approval from the Fire Marshall and incorporation of sprinkled log decks. It is anticipated that the expansion area would contain 12 log decks: nine (9) on Quail Meadows and three (3) on APN: 108-040-18. These decks would be approximately 250 to 300 feet in length with a proposed height of 30 feet. Additionally, water supplies available for fire suppression needs would include three (3) existing wells at the Site, one (1) existing well at the existing log yard, up to three (3) wells proposed at the Site, and the proposed irrigation ponds.

Based on correspondence received from Eric Alvarez, Fire Marshal/Division Chief of the Little Lake Fire District in March 2023 (see Appendix K), the Project would also be required to provide a minimum fire flow of 4,500

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
gpm at 20 pounds per square inch (psi) for approximately 6 hours. Additionally, it is noted that the type of hydrant required for the Project is a standard municipal hydrant with two (2) 2½-inch outlets and one (1) 4½- inch outlet, with spacing required to be 600 feet apart. Furthermore, it is noted that backup power to the fire pump is essential to ensure the fire pump would remain in proper working order for fire suppression efforts (2023).

Four (4) City fire hydrants are located within the vicinity of the Site, with the closest hydrant located approximately 200 feet southwest of the existing office structure. The Applicant intends to install additional log-yard fire hydrants such that no log deck is greater than 500 feet from a City or log-yard fire hydrant. It is anticipated that the proposed irrigation ponds would store water for use in the log-yard fire hydrant system, when needed. A log irrigation system with low flow sprinklers is anticipated to be utilized approximately 8 hours per day to wet the log decks. The Applicant anticipates that the four (4) existing wells would be sufficient for meeting the needs of the current and expanded log yards, with the proposed irrigation ponds available as a back-up supply.

Development of the Site for a typical industrial facility would generally include vegetation removal; grading for access roads, building pads, and parking areas; landscaping; installation of water storage facilities such as water tanks and/or ponds to serve as back-up water supplies and for fire suppression needs; reuse and/or removal of existing structures; infrastructure improvements related to water supply, wastewater, solid waste, and storm drainage; regular maintenance activities; and in many cases, construction of new structures.

Building permit applications for a typical industrial facility would be subject to review by the Little Lake Fire District for compliance with the current version of the CFC in place at the time of building permit application submittal. Typical conditions would be anticipated to be related to maintaining site access and circulation for emergency equipment, emergency water supply, property signage, flammable materials storage, and other conditions as required by the Fire Marshal in accordance with the current CFC at the time a project is proposed.

XX.a) There are no components of the Project that are likely to impact an adopted emergency response plan or emergency evacuation plan. The proposed Project and other typical industrial facilities would be required to meet State and local standards for defensible space and emergency access and provide hydrants in accordance with the requirements specified above. Additionally, Mitigation Measure HAZ-1 requires the preparation of an EAP for the Project and future projects, as they occur, to the satisfaction of the Little Lake Fire District. By meeting current standards and design requirements, incorporation of Mitigation Measure HAZ-1, and since sufficient fire protection services are available to serve the Site, a less than significant impact would occur.

XX.b) As noted above, the Site is relatively flat and is not located within a very high fire hazard severity zone.

The proposed Project and other typical industrial facilities would be developed in accordance with the City Code and the latest CBC and CFC. There are no factors, such as steep slopes, prevailing winds, or the installation/maintenance of new infrastructure, which would exacerbate fire risk or expose future occupants of the Site to the uncontrolled spread of a wildfire, pollutant concentrations from a wildfire, post-fire slope instability, or post-fire flooding. Therefore, the Project and other typical industrial facilities would have a less than significant impact.

XX.c) The Site is currently and, under the Project, would continue to be served by electricity, natural gas, community wastewater, and solid waste service provided by local providers, in addition to on-site wells. The Site contains existing utility lines. Although electrical upgrades may be necessary for the Project, it is not anticipated that fire risk would be exacerbated or that temporary or ongoing impacts to the environment

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
would occur, as the relevant utility providers would be required to employ applicable BMPs to ensure potential impacts are minimized. A less than significant impact would occur.

Other typical industrial facilities would not be anticipated to require the installation or maintenance of associated infrastructure that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment. Building permit applications for a typical industrial facility would be subject to review by the Little Lake Fire District for compliance with the current version of the CFC in place at the time of building permit application submittal to ensure that site design and improvements for future projects do not exacerbate fire risk.

XX.d) The proposed Project and other typical industrial facilities would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage challenges, as the Site is relatively flat. Additionally, as previously discussed, stormwater for the Project would be collected and retained on-site in the two (2) ponds proposed at the Site. Due to the size of the Site and the nature of industrial uses, it can be assumed that construction activities of other typical industrial facilities would cause disturbance to greater than 1 acre of land and would therefore be required to comply with the CGP, which would ensure that BMPs would be implemented in accordance with a project-specific SWPPP to reduce the risk of soil erosion and loss of topsoil. The Project would also be required to comply with the CGP. A less than significant impact would occur.

MITIGATION MEASURES
Refer to Mitigation Measure HAZ-1 under Section IX (Hazards and Hazardous Materials), above.

FINDINGS
The proposed Project and other typical industrial development would have a Less Than Significant Impact With Mitigation Incorporated on Wildfire.

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
XXI. MANDATORY FINDINGS OF SIGNIFICANCE. Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Does the project have the potential to substantially degrade the quality of the environment, substantially
reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below selfsustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number
or restrict the range of a rare or endangered plant or
animal or eliminate important examples of the major
periods of California history or prehistory?
b) Does the project have impacts that are individually
limited, but cumulatively considerable?
(“Cumulatively considerable” means that the
incremental effects of a project are considerable
when viewed in connection with the effects of past
projects, the effects of other current projects, and the effects of probable future projects).
c) Does the project have environmental effects, which
will cause substantial adverse effects on human
beings, either directly or indirectly?

DISCUSSION
Certain mandatory findings of significance must be made to comply with CEQA Guidelines §15065. The proposed Project has been analyzed, and it has been determined that it would not:
• Substantially degrade environmental quality;
• Substantially reduce fish or wildlife habitat;
• Cause a fish or wildlife population to fall below self-sustaining levels; • Threaten to eliminate a plant or animal community;
• Reduce the numbers or range of a rare, threatened, or endangered species; • Eliminate important examples of the major periods of California history or pre-history; • Achieve short term goals to the disadvantage of long term goals; • Have environmental effects that will directly or indirectly cause substantial adverse effects on human • beings; or
• Have possible environmental effects that are individually limited but cumulatively considerable when viewed in connection with past, current, and reasonably anticipated future projects.

Potential environmental impacts would be related to the expansion of existing log yard operations to support local timber harvesting operations and increase log purchasing and storage capacity in the region and other typical industrial facilities that may occur due to the GPA and Rezone. The Applicant has identified the Site as an ideal location for an expanded log yard due to its location adjacent to a Highway 101 off-ramp, existing access roads to and within the Site, the surrounding uses and development, and the existing utility connections at the Site. As the Site is located at the northern end of the Willits city limits adjacent to a Highway 101 off-ramp, the Site would be easily accessed from the surrounding region, without increasing truck traffic through the City of Willits. Potential environmental impacts have been analyzed in this document and mitigation measures have been included in the document to ensure impacts would be held to a less than significant level.

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
XXI.a) The Project and other typical industrial facilities would not have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory. There are no important examples of California Pre-history or history located on the Site. While portions of the Site are mapped as wetlands and contain sensitive species that may be impacted by the Project and other typical industrial facilities, mitigation has been applied to reduce any potential environmental impacts to levels that are less than significant.

XXI.b) No cumulative impacts have been identified as a result of the proposed Project. The Project is intended to facilitate expansion of the existing log yard to the south. Based on the analysis in this IS, it is anticipated that potential impacts from the Project and other typical industrial facilities would be less than significant and would not contribute to significant cumulative impacts. All potential impacts have been mitigated to less than significant levels.

Other projects in the general vicinity of the Site that may contribute to cumulative impacts include the City’s Land Use Element Update to the City of Willits General Plan (1992). However, it is not anticipated that the Project and other typical industrial facilities would result in cumulative impacts, as impacts identified in this IS would be localized and mitigated to less than significant. Additionally, if the City’s Land Use Element Update facilitates land use designations in the vicinity of the Site, development at the Site would be required to comply with applicable setbacks. There are no other known projects in the general vicinity of the Site that may cause a cumulative impact.

XXI.c) Based on the findings in this Initial Study and as mitigated and conditioned, the proposed Project and other typical industrial facilities would not have environmental effects that would cause substantial adverse effects on human beings either directly or indirectly. Potential environmental impacts associated with approval of the Project and other typical industrial facilities have been analyzed and as mitigated, all potential impacts can be reduced to a less-than-significant level.

MITIGATION MEASURES
Refer to Mitigation Measures BIO-1 through BIO-8 in Section IV (Biological Resources), CUL-1 through CUL-3 in Section V (Cultural Resources), GEO-1 in Section VII (Geology and Soils), HAZ-1 in Section IX (Hazards and Hazardous Materials), and NOI-1 and NOI-2 in Section XIII (Noise), above.

FINDINGS
The proposed Project and other typical industrial facilities would have a Less Than Significant Impact with Mitigation Incorporated on Mandatory Findings of Significance.

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
VI. REFERENCES
Alvarez, Eric (Fire Marshal/Division Chief) – Little Lake Fire Protection District. March 17, 2023. Letter Correspondence. (Appendix K)
Browning Cultural Resources, Inc. (BCR). August 21, 2020. Quail Meadows Parcel, APN: 108-040-11-00, Willits, California, Cultural Resources Inventory. (On file and confidential) Browning Cultural Resources, Inc. (BCR). March 29, 2021. Schwindt Parcel, APN: 108-040-18, Willits, California, Cultural Resources Inventory. (On file and confidential) California Air Resources Board (CARB). 2018. AB 32 Scoping Plan. Accessed February 23, 2022. Available at:
https://ww3.arb.ca.gov/cc/scopingplan/scopingplan.htm.

California Air Resources Board (CARB). 2019. GHG Current California Emission Inventory Data. California Greenhouse Gas Emissions for 2000 to 2017. Accessed February 23, 2022. Available at:
https://ww3.arb.ca.gov/cc/inventory/pubs/reports/2000_2017/ghg_inventory_trends_00-17.pdf.

California Department of Conservation (DOC). December 2002. California Geological Survey. Note 36:

California Geomorphic Provinces. Accessed April 26, 2023. https://www.conservation.ca.gov/cgs/Documents/Publications/CGS-Notes/CGS-Note-36.pdf.

California Department of Conservation (DOC). 2015 (a). DOC Maps: Geologic Hazards. Fault Activity Map of California. Accessed April 26, 2023. Available at: https://maps.conservation.ca.gov/cgs/fam/.

California Department of Conservation (DOC). 2015 (b). California Geological Survey. Mineral Land Classification Studies Index. Accessed April 24, 2023. Available at:
https://maps.conservation.ca.gov/cgs/informationwarehouse/index.html?map=mlc.

California Department of Conservation (DOC). 2016 (a). Farmland Mapping & Monitoring Program.

California Important Farmland Finder. Accessed April 25, 2023. Available at:
https://maps.conservation.ca.gov/DLRP/CIFF/.

California Department of Conservation (DOC). 2016 (b). DOC Maps: Geologic Hazards. Earthquake Zones of Required Investigation. Accessed April 26, 2023. Available at:
https://maps.conservation.ca.gov/cgs/EQZApp/.

California Department of Fish and Wildlife (CDFW). 2025. California Endangered Species Act (CESA) Permits.

Accessed August 6, 2025. Available at:
https://wildlife.ca.gov/Conservation/CESA/Permitting#550391512-memorandum-of-understandingmou--2081-a.

California Department of Forestry and Fire Protection (CAL FIRE). April 1, 2024. Fire Hazard Severity Zone Viewer. Accessed April 3, 2025. Available at:
https://experience.arcgis.com/experience/03beab8511814e79a0e4eabf0d3e7247/.

California Department of Toxic Substances Control (DTSC). 2023. EnviroStor. Accessed April 25, 2023.

Available at: https://www.envirostor.dtsc.ca.gov/public/. (Appendix G) Revised Draft CEQA Initial Study
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
California Department of Transportation (Caltrans). 2023. California State Scenic Highways. Accessed March 21, 2023. Available at: https://dot.ca.gov/programs/design/lap-landscape-architecture-andcommunity-livability/lap-liv-i-scenic-highways.

California Department of Water Resources Control Board (SWRCB). 2023. GeoTracker. Accessed March 21, 2023. Available at:
https://geotracker.waterboards.ca.gov/map/?CMD=runreport&myaddress=Willits. (Appendix G) California Energy Commission (CEC). October 2017. California Energy Commission Final Commission Report - Senate Bill 350: Doubling Energy Efficiency Savings by 2020. Accessed February 28, 2022. Available at: http://docketpublic.energy.ca.gov/PublicDocuments/17-IEPR06/TN221631_20171026T102305_Senate_Bill_350_Doubling_Energy_Efficiency_Savings_by_2030.pdf.

California Energy Commission (CEC). 2021. 2022 Building Energy Efficiency Standards. Accessed March 28, 2023. Available at: https://www.energy.ca.gov/programs-and-topics/programs/building-energyefficiency-standards/2022-building-energy-efficiency.

City of Willits. No Date (a). Willits General Plan Land Use Diagram. Accessed April 25, 2021. Available at:
https://cityofwillits.org/DocumentCenter/View/615/General-Plan-Map.

City of Willits. No Date (b). City of Willits Zoning Map. Accessed April 25, 2023. Available at:
http://www.willitsairport.com/DocumentCenter/View/263/Zoning-Map.

City of Willits. No Date (c). Police Department. Accessed April 25, 2023. Available at:
https://cityofwillits.org/148/Police.

City of Willits. 1992. Willits General Plan. Accessed April 25, 2023. Available at:
https://cityofwillits.org/DocumentCenter/View/262/City-of-Willits-General-Plan.

City of Willits. November 12, 2011. Public Works and Engineering Department. 100% DRAFT City of Willits Design and Construction Standards. Accessed March 30, 2023. Available at:
https://cityofwillits.org/DocumentCenter/View/227/Construction-Standards-COMPLETE-BOOK-.

City of Willits. 2019 (a). City of Willits General Plan: 2019 Safety Element. Accessed April 25, 2023. Available at: https://cityofwillits.org/DocumentCenter/View/584/2019-General-Plan-Safety-Element-Update--- Public-Review-Draft-.

City of Willits. 2019 (b). City of Willits General Plan: 2019-2027 Housing Element Update. Accessed April 25, 2023. Available at: https://cityofwillits.org/DocumentCenter/View/522/Housing-Element-2019-2027- Adopted.

City of Willits. Updated 2021. Code of Ordinances. Accessed April 25, 2023. Available at:
https://library.municode.com/ca/willits/codes/code_of_ordinances.

Clifton, Estelle P. September 27, 2022. Clifton Environmental LLC. Biological Resources Assessment. (Appendix C)
Revised Draft CEQA Initial Study
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
County of Mendocino. 1991. Department of Planning & Building Services. Zoning Ordinance. Accessed March 21, 2023. Available at: https://www.mendocinocounty.org/government/planning-buildingservices/regulations/zoning-code/inland.

County of Mendocino. Revised June 6, 1996. Mendocino County Airport Comprehensive Land Use Plan.

Accessed May 12, 2023. Available at:
https://www.mendocinocounty.org/home/showpublisheddocument/15179/636487675093000000.

County of Mendocino. Revised 2020. Mendocino County General Plan: Development Element. Accessed April 25, 2023. Available at:
https://www.mendocinocounty.org/home/showpublisheddocument/54479/638055061911270000.

County of Mendocino. Revised 2020. Mendocino County General Plan: Resource Management Element.

Accessed May 1, 2023. Available at:
https://www.mendocinocounty.org/home/showpublisheddocument/54487/638055061981600000.

Federal Emergency Management Agency (FEMA). No Date. FEMA Flood Map Service Center. Accessed March 17, 2023. Available at: https://msc.fema.gov/portal/home. (Appendix H) Google Earth. March 22, 2023. 39°25'12.73ʺ N, 123° 21ʹ 10.74ʺ W. Accessed March 22, 2023.

Available at: https://www.google.com/earth/versions/.

LACO Associates. August 18, 2020. Little Lake Valley Groundwater Management Plan. Accessed April 20, 2023. Available at: https://cityofwillits.org/DocumentCenter/View/784/Final-Little-Lake-ValleyGroundwater-Management-Plan.

Little Lake Fire District. 2023. Little Lake Fire District. Accessed April 25, 2023. Available at:
https://www.littlelakefire.org/.

Mendocino County Air Quality Management District (MCQAMD). January 2005. Particulate Matter Attainment Plan. Accessed February 23, 2022. Available at:
http://www.co.mendocino.ca.us/aqmd/pdf_files/Attainment%20Plan_DRAFT.pdf.

Mendocino County Air Quality Management District (MCAQMD). February 2011. Rules and Regulations.

Regulation 1 – Air Pollution Control Rules. Accessed February 25, 2022. Available at:
http://www.co.mendocino.ca.us/aqmd/district-regulation-1.html.

Mendocino County Executive Office, Office of Recovery, and Office of Emergency Services. Approved February 4, 2021. Accessed March 23, 2023. Available at: https://mitigatehazards.com/mendocinocounty/final-mjhmp/.

North Coast Regional Water Quality Control Board (NCRWQCB). December 2, 2021. NPDES No. CA0023060.

Accessed April 13, 2023. Available at:
https://www.waterboards.ca.gov/northcoast/board_decisions/adopted_orders/pdf/2021/2121willit sNPDES.pdf.

Thomson Reuters Westlaw. 2005. California Code of Regulations. Title 13, Division 3, Chapter 10, Article 1, Revised Draft CEQA Initial Study
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
Section 2485: Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling.

Accessed February 25, 2022. Available at: https://www.law.cornell.edu/regulations/california/CalCode-Regs-Tit-13-SS-2485.

United States Department of Agriculture (USDA), Natural Resources Conservation Service (NRCS). July 21, 2019. Web Soil Survey. Accessed March 23, 2023. Available at:
https://websoilsurvey.sc.egov.usda.gov/App/HomePage.htm.

W-Trans. May 16, 2023. Draft Focused Transportation Impact Study for the Sanhedrin Timber Company Entitlements Project. (Appendix E)
Willits Unified School District. 2023. Willits Unified School District. Accessed April 25, 2023. Available at:
https://www.willitsunified.com/.

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025

FIGURES
Figure 1 Project Location Map
Figure 2 Vicinity Map
Figure 3 General Plan Amendment Figure
Figure 4 Rezone Figure
Figure 5 Site Plan
Revised Draft CEQA Initial Study
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025

APPENDIX A
Tree Survey
Revised Draft CEQA Initial Study
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025

APPENDIX B
Photo Log
Revised Draft CEQA Initial Study
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025

APPENDIX C
Biological Resources Assessment
Revised Draft CEQA Initial Study
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025

APPENDIX D
Mitigation and Monitoring Program (MMRP)
Revised Draft CEQA Initial Study
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025

APPENDIX E
Focused Transportation Impact Study
Revised Draft CEQA Initial Study
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025

APPENDIX F
Native American Heritage Commission Sacred Lands
File Search and Contact List
Revised Draft CEQA Initial Study
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025

APPENDIX G
GeoTracker and EnviroStor Database Queries
Revised Draft CEQA Initial Study
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025

APPENDIX H
FEMA Flood Insurance Rate Map (FIRM)
Revised Draft CEQA Initial Study
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025

APPENDIX I
Well Impact Report
Revised Draft CEQA Initial Study
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025

APPENDIX J
Environmental Noise Assessment
Revised Draft CEQA Initial Study
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025

APPENDIX K
Little Lake Fire District Correspondence

City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025

F I G U R E S
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CHECK
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REU SEOFDOCU MEN TS:Thisd oc um e ntand the id e asand d e sig n inc orp orate d he re in,asan instrum e nto fp ro fe ssio nalse rvic e ,isthe p rop e rty o f LACO Asso c iate sand shallno tb e re use d in whole o r p artfo r any othe r p ro je c t witho utLACO Asso c iate se xp re sswritte n autho rizatio n.

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1-800-515-5054 www.lac o asso c iate s.c o m

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LOCATION

FIGU RE
JOBN O.

USGS The National Map: National Boundaries Dataset, 3DEP Elevation Program, Geographic Names Information System, National
Hydrography Dataset, National Land Cover Database, National Structures Dataset, and National Transportation Dataset; USGS Global Ecosystems; U.S. Census Bureau TIGER/Line data; USFS Road Data; Natural Earth Data; U.S. Department of State Humanitarian Information Unit; and NOAA National Centers for Environmental Information, U.S.

Coastal Relief Model. Data refreshed August, 2021.
123°21'30"W 123°21'0"W 123°20'30"W 123°20'0"W
39°26'0"N
39°25'30"N
39°25'0"N
39°24'30"N

P ROJECTLOCATION
09/27/2022
10226.00

SAN HEDRIN TIMBEREN TITLEMEN TS

SAN HEDRIN TIMBERCOMP AN Y
23701N HIGHWAY101,WILLITS,CA
AAM
RMD 1
1-800-515-5054 www.lacoassocociates.com
N OTE:THEIN FORMATION ILLU STRATED

IN THISMAP WASDERIVEDFROM
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CAN N OTGU ARAN TEETHEACCU RACY
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P ROJECT
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SantaRosa,CA,7.5-m inute U SGSTop og rap hic Quad rang le Sources: Esri, HERE, Garmin,
USGS, Intermap, INCREMENT P,
NRCan, Esri Japan, METI, Esri
China (Hong Kong), Esri Korea,
Esri (Thailand), NGCC, (c)
OpenStreetMap contributors, and
the GIS User Community

P ROJECTLOCATION
0 625 1,250 2,500 3,750 5,000
Fe e t
BY
CHECK
DATE
REUSEOFDOCUMENTS:This d ocum e ntand the id e as and d e s ig n incorp orate d he re in,as an instrum e nto f p ro fe s s io nalse rvice ,is the p rop e rtyo f LACO As so ciate s and s hallno tbe re us e d in whole o rp artfo ranyothe rp ro je ct witho utLACO Ass o ciate s e xp re s s writte n autho rizatio n.

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1-800-515-5054 www.laco as s o ciate s .co m

P ROJECT
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LOCATION
FIGURE
JOBNO.

Sanhe d rin Tim be rEntitle m e nts AAM
RMD
09/27/2022
2 10226.00
Note :

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was d e rive d from publicly-available
GISd ata.LACOAssociate s cannot
g uarante e the accuracyof the d ata.
0 200 400 800Fe e t
Sanhe d rin Tim be rCom pany,LLC
23701North Hig hway101/Main Stre e t
VicinityMap
Source s:Goog le Earth,Me nd ocino County

P ROJECT
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FIGUREJO BNO .

BYCHECKDATE

PRO JECTCLIENTLO CATIO N
L
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1-800-515-5054 w
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Sou rce s:Goog le Ea rth,Me ndocino Cou nty

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APN108-040-11
APN:108-040-18 APN:108-040-18
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Pu b licFa cility(PF)
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wa sde rive dfrom p u b licly-a va ila b le
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BYCHECKDATE

PRO JECTCLIENTLO CATIO N
L
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C
O EUREKA ● UKIA
H ● SA

NTARO SA
1-800-515-5054 w
w
w.la co a sso cia te s.co m
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Sou rce s:Goog le Ea rth,Me ndocino Cou nty
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APN108-040-18
APN108-040-11
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BY
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REUSEO FDO CUMENTS:Thisd oc um e ntand the id e asand d e sig n inc orp orate d he re in,asan instrum e nto f p ro fe ssio nalse rvic e ,isthe p rop e rty o f LACO Asso c iate sand shallno tbe re use d in whole o r p artfo r any othe r p ro je c t witho utLACO Asso c iate se xp re sswritte n autho rizatio n.

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1-800-515-5054 www.lac o asso c iate s.c o m

PRO JECT
CLIENT

LO CATIO N
FIGURE
JO BNO .

Sanhe d rin Tim be r Entitle m e nts AM
RMD
04/05/2024
5 10226.00
!? Existing We ll
!? Proposed Wells
Fire Hyd rant
% Wate r Tank/Pre ssure Pum p
Inte rnalAc c e ssRoad
Existing Drainage
Prop ose d Drainag e Ditc h
! ! PVCPre ssure Line
We llPum p Line
Bound aryLine Ad justm e nt
Bark Piles
Storage Container
Parking Are a
Log De c k
Pond
Existing Log Yard
Proje c tParc e ls
Note :

The inform ation illustrate d in thism ap
wasd e rive d from public ly-available
GISd ata.LACO Assoc iate sc annot
guarante e the ac c urac yof the d ata.
0 125 250 500Fe e t
Sanhe d rin Tim be r Com pany,LLC
23701North Highway101/Main Stre e t
Site Plan
Caste e lLane
Main
Stre e t

2.2 acres

19.05 acres
Sourc e :USGSEarth Explore r
P P P
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De re lic tte nnis
c ourtsto be
re m ove d
Note :

Thissite p lan re fle c tsthe ge ne ral
layoutof p ropose d site fe ature s.

Se e Grad ing &Drainage p lans
pre pare d byPope Engine e ring
for d e taile d inform ation.
1,500SFoffic e
to be re taine d
QuailMe ad ows
e ntranc e
Fue ltank to
pote ntiallybe
re loc ate d he re
6,900SF
storag e units
to be re m ove d
Lotline to be re loc ate d
pe r BLATe ntative Map
pre pare d byPop e
Eingine e ring
Propose d bound aryline
Ad juste d parc e lpe r
BLATe ntative Map
pre pare d byPop e
Engine e ring
Wate r Syste m
asshown on
Pop e
Engine e ring
Plans
Existing fue l
tank,m aybe
re loc ate d
Revised Draft CEQA Initial Study
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025

A P P E N D I X A
T r e e S u r v e y
1 9
99 98 97
94 93
92 8889
87 85
84 83
82 81
80 79
78 77
76 75
7374
68 67
63 60
56 52 51
50 44
41 40
37 36 30
27 21
17 16
15 10
362
360
359
358
357
355 353
352 351 350
349 348
347
346 345 344
342343
341
340 339
338
337
336 334 333
332
330331
329
328
325 326 327
324 323
318
317 316
313
312
311
310 309
308
307
304305 306
302
301
300
299 298
297 296
295 294
291
290
289 288
285
284
283
282
281
280 279
277 278
276
275 274
273
272
271
270
269
267268
266
265
264
261
260 258
257 256 253
252
251
250
249
248
247
246
244 245
243
242
239
236 235
231
228
226
225
222 221
220
219
218
217215
214
213 212
210 209 208
207204
203 202
201 200
199 198
196197
195 191
185 188
184
183
182 181
178
175174
173
172
171 167
162164165
160
159
156
155
152
134 133
127 129128 130
126
125 115 116
114
111
110
109
106
105
104
103
102 101
100
4&52&3
90,91
69-72
61,62
45,46
42,43
38,39
28,29
13&14
11&12 6,7,8
363,364
286,287
254,255
240,241
237,238
229,230
189,190
186,187
179,180
176,177
157,158
143,144
141,142 139,140
131,132
123,124
121,122
107,108
57,58,59
53,54,55
18,19,20
232,233,234
192,193,194
22,23,24,25,26
135,136,137,138
117,118,119,120
US Hwy 101
Redwood Hwy
Tree Survey Map
1185 Maple Creek Road
Korbel, California 95550
T18N R13W Sections 7 &18 MDBM
±
1 inch = 175 feet
1:2,100
Map Point
N. Main Street
Internal Access Roads
Parcel Boundary
Victor Hollister RPF #3180
April 2023
*Map Points shaded in blue denote retention trees
Tree # Common Name Scientific Name DBH (in.) Height (ft.) Retained (Y/N) 1 Bigtooth aspen Populus tremula 17.6 47 No
2 Bigtooth aspen Populus tremula 21.4 65 No
3 Bigtooth aspen Populus tremula 14.5 41 No
4 Bigtooth aspen Populus tremula 17.3 63 No
5 Bigtooth aspen Populus tremula 11.5 38 No
6 Bigtooth aspen Populus tremula 20.1 58 No
7 Bigtooth aspen Populus tremula 16.5 66 No
8 Bigtooth aspen Populus tremula 19.9 60 No
9 Bigtooth aspen Populus tremula 26.2 60 No
10 Bigtooth aspen Populus tremula 28.1 36 No
11 Black willow Salix nigra 16.0 33 No
12 Black willow Salix nigra 16.4 35 No
13 Black willow Salix nigra 20.0 29 No
14 Black willow Salix nigra 9.4 26 No
15 Bigtooth aspen Populus tremula 29.3 54 No
16 London plane tree Plananus hispanica 20.5 54 Yes
17 Austrian pine Pinus nigra 30.0 41 No
18 Non-native maple Acer spp. 16.0 66 Yes
19 Non-native maple Acer spp. 17.6 65 Yes
20 Non-native maple Acer spp. 19.0 66 Yes
21 California black oak Quercus kelloggii 14.4 30 No
22 Chinese juniper Juniperus chinensis 8.5 21 No
23 Chinese juniper Juniperus chinensis 6.5 21 No
24 Chinese juniper Juniperus chinensis 12.5 21 No
25 Chinese juniper Juniperus chinensis 6.0 21 No
26 Chinese juniper Juniperus chinensis 10.6 21 No
27 Non-native maple Acer spp. 19.7 70 No
28 Non-native maple Acer spp. 16.3 70 No
29 Non-native maple Acer spp. 23.6 75 No
30 Austrian pine Pinus nigra 13.6 23 No
31 Non-native maple Acer spp. 14.0 58 No
32 Non-native maple Acer spp. 15.5 54 No
33 Non-native maple Acer spp. 7.0 20 No
34 Non-native maple Acer spp. 16.4 60 No
35 Non-native maple Acer spp. 12.8 56 No
36 Ponderosa pine Pinus ponderosa 24.9 71 No
37 Olive Olea europaea 7.8 12 No
38 Non-native maple Acer spp. 18.5 81 Yes
39 Non-native maple Acer spp. 14.0 74 Yes
40 Non-native maple Acer spp. 24.3 82 Yes
41 Non-native maple Acer spp. 14.3 48 No
42 Non-native maple Acer spp. 16.4 51 No
43 Non-native maple Acer spp. 17.5 58 No
44 Walnut Juglans spp. 13.0 39 No
45 Lombardy poplar Populus nigra 6.0 40 No
46 Lombardy poplar Populus nigra 7.1 31 No
47 Lombardy poplar Populus nigra 10.1 45 No
48 Lombardy poplar Populus nigra 8.6 52 No
49 Lombardy poplar Populus nigra 8.4 58 No
50 Ponderosa pine Pinus ponderosa 14.5 42 No
51 Oregon ash Fraxinus latifolia 22.0 38 No
52 American sycamore Platinus occidentalis 17.9 70 No
53 Non-native maple Acer spp. 17.3 69 No
54 Non-native maple Acer spp. 9.1 52 No
55 Non-native maple Acer spp. 16.2 68 No
56 Non-native maple Acer spp. 28.2 73 No
57 Black willow Salix nigra 11.8 33 No
58 Black willow Salix nigra 9.0 31 No
59 Black willow Salix nigra 9.7 25 No
60 Black willow Salix nigra 13.0 41 No
61 Black willow Salix nigra 16.7 41 No
62 Black willow Salix nigra 8.4 35 No
63 Sweet gum Liquidambar styracifula 7.3 37 No
64 Black willow Salix nigra 8.2 32 No
65 Black willow Salix nigra 10.6 32 No
66 Black willow Salix nigra 8.6 31 No
67 Sweet gum Liquidambar styracifula 11.1 44 No
68 Black willow Salix nigra 14.0 40 No
69 Non-native maple Acer spp. 6.0 36 No
70 Non-native maple Acer spp. 8.2 39 No
71 Non-native maple Acer spp. 8.7 37 No
72 Non-native maple Acer spp. 6.5 33 No
73 Non-native maple Acer spp. 19.0 57 No
74 Black willow Salix nigra 10.1 36 No
75 Non-native maple Acer spp. 11.9 40 No
76 Black poplar Populus nigra 21.8 87 No
77 Black poplar Populus nigra 24.2 88 No
78 Black poplar Populus nigra 20.0 88 No
79 Black poplar Populus nigra 22.3 89 No
80 Black poplar Populus nigra 24.3 84 No
81 Black poplar Populus nigra 25.4 82 No
82 Non-native maple Acer spp. 8.6 37 No
83 Black poplar Populus nigra 14.2 85 No
84 Black poplar Populus nigra 21.6 88 No
85 Black poplar Populus nigra 22.6 86 No
86 Black poplar Populus nigra 24.9 83 No
87 Ponderosa pine Pinus ponderosa 10.3 36 No
88 Black poplar Populus nigra 28.1 92 No
89 Black poplar Populus nigra 23.5 86 No
90 Black poplar Populus nigra 22.7 79 No
91 Black poplar Populus nigra 18.6 75 No
92 Austrian pine Pinus nigra 10.0 41 No
93 Black poplar Populus nigra 30.8 93 No
94 Black poplar Populus nigra 16.1 51 No
95 Black poplar Populus nigra 22.8 108 No
96 Black poplar Populus nigra 19.8 102 No
97 Non-native maple Acer spp. 15.5 45 No
98 Black poplar Populus nigra 26.2 99 No
99 American sycamore Platinus occidentalis 20.2 74 No
100 American sycamore Platinus occidentalis 15.8 72 No
101 American sycamore Platinus occidentalis 14.0 65 No
102 American sycamore Platinus occidentalis 13.8 66 No
103 Non-native maple Acer spp. 21.6 41 No
104 American sycamore Platinus occidentalis 16.4 81 No
105 Black poplar Populus nigra 19.9 92 No
106 Black poplar Populus nigra 23.0 79 No
107 Black poplar Populus nigra 22.7 84 No
108 Black poplar Populus nigra 20.9 82 No
109 Non-native maple Acer spp. 14.6 46 No
110 Non-native maple Acer spp. 13.0 41 No
111 Non-native maple Acer spp. 16.7 48 No
112 Sweet gum Liquidambar styracifula 10.0 56 No
113 Sweet gum Liquidambar styracifula 9.8 54 No
114 Black willow Salix nigra 17.0 46 No
115 Black willow Salix nigra 17.2 34 No
116 Apple tree Malus domesticata 10.5 23 No
117 Black willow Salix nigra 12.09 No
118 Black willow Salix nigra 13.1 26 No
119 Black willow Salix nigra 11.8 12 No
120 Black willow Salix nigra 10.9 18 No
121 Black willow Salix nigra 17.1 35 No
122 Black willow Salix nigra 11.8 22 No
123 Black willow Salix nigra 14.0 27 No
124 Black willow Salix nigra 10.6 21 No
125 Black willow Salix nigra 18.0 32 No
126 Oregon ash Fraxinus latifolia 9.1 33 No
127 California black oak Quercus kelloggii 10.6 40 No
128 California black oak Quercus kelloggii 10.9 44 No
129 Black willow Salix nigra 9.8 28 No
130 Black willow Salix nigra 6.6 32 No
131 Black poplar Populus nigra 11.6 17 No
132 Black poplar Populus nigra 19.5 84 No
133 Black poplar Populus nigra 31.0 93 No
134 Black poplar Populus nigra 28.3 90 No
135 Non-native maple Acer spp. 6.7 42 No
136 Non-native maple Acer spp. 7.4 43 No
137 Non-native maple Acer spp. 7.7 42 No
138 Non-native maple Acer spp. 7.0 35 No
139 Non-native maple Acer spp. 12.0 56 No
140 Non-native maple Acer spp. 8.3 50 No
141 Non-native maple Acer spp. 6.7 42 No
142 Non-native maple Acer spp. 6.5 40 No
143 Non-native maple Acer spp. 8.7 40 No
144 Non-native maple Acer spp. 8.5 43 No
145 Bigtooth aspen Populus tremula 20.3 57 No
146 Bigtooth aspen Populus tremula 16.1 52 No
147 Bigtooth aspen Populus tremula 23.9 56 No
148 Bigtooth aspen Populus tremula 23.2 60 No
149 Bigtooth aspen Populus tremula 15.7 50 No
150 Bigtooth aspen Populus tremula 20.1 55 No
151 Bigtooth aspen Populus tremula 14.0 45 No
152 Sweet gum Liquidambar styracifula 10.9 61 No
153 Black poplar Populus nigra 15.8 81 No
154 Black poplar Populus nigra 13.6 72 No
155 Black poplar Populus nigra 21.4 87 No
156 Black poplar Populus nigra 18.3 87 No
157 Black willow Salix nigra 6.0 20 No
158 Black willow Salix nigra 11.6 37 No
159 Black willow Salix nigra 6.4 31 No
160 California black oak Quercus kelloggii 34.6 66 No
161 Black poplar Populus nigra 14.9 70 No
162 Black poplar Populus nigra 18.9 70 No
163 Black poplar Populus nigra 10.0 52 No
164 Black poplar Populus nigra 11.5 59 No
165 Black poplar Populus nigra 11.5 61 No
166 Non-native maple Acer spp. 9.9 73 No
167 Black poplar Populus nigra 13.7 72 No
168 Non-native maple Acer spp. 7.2 42 No
169 Non-native maple Acer spp. 9.5 58 No
170 Non-native maple Acer spp. 6.2 48 No
171 Black poplar Populus nigra 11.9 70 No
172 Black poplar Populus nigra 17.0 70 No
173 Black poplar Populus nigra 16.9 66 No
174 Black poplar Populus nigra 17.2 76 No
175 Black poplar Populus nigra 14.8 70 No
176 Black poplar Populus nigra 11.5 64 No
177 Black poplar Populus nigra 11.6 66 No
178 Black poplar Populus nigra 16.6 72 No
179 Black poplar Populus nigra 13.9 74 No
180 Black poplar Populus nigra 15.0 70 No
181 Black poplar Populus nigra 17.1 73 No
182 Black poplar Populus nigra 13.8 75 No
183 Black poplar Populus nigra 14.6 71 No
184 Black poplar Populus nigra 23.8 84 No
185 Black willow Salix nigra 12.7 34 No
186 Black willow Salix nigra 9.5 34 No
187 Black willow Salix nigra 10.1 40 No
188 Black willow Salix nigra 13.8 40 No
189 Black willow Salix nigra 10.2 32 No
190 Black willow Salix nigra 7.6 30 No
191 California black oak Quercus kelloggii 8.4 62 Yes
192 ornamental Cypress Cupressus spp. 14.5 52 Yes
193 ornamental Cypress Cupressus spp. 11.2 41 Yes
194 ornamental Cypress Cupressus spp. 17.5 50 Yes
195 ornamental Cypress Cupressus spp. 23.8 70 Yes
196 ornamental Cypress Cupressus spp. 18.9 71 Yes
197 ornamental Cypress Cupressus spp. 21.3 70 Yes
198 ornamental Cypress Cupressus spp. 18.1 75 Yes
199 ornamental Cypress Cupressus spp. 19.4 73 Yes
200 ornamental Cypress Cupressus spp. 19.9 74 Yes
201 ornamental Cypress Cupressus spp. 19.7 68 Yes
202 ornamental Cypress Cupressus spp. 19.0 77 Yes
203 ornamental Cypress Cupressus spp. 17.3 73 Yes
204 ornamental Cypress Cupressus spp. 24.1 71 Yes
205 ornamental Cypress Cupressus spp. 10.3 51 Yes
205.1 ornamental Cypress Cupressus spp. 13.7 70 Yes
205.2 ornamental Cypress Cupressus spp. 11.5 68 Yes
206 ornamental Cypress Cupressus spp. 21.7 75 Yes
207 ornamental Cypress Cupressus spp. 19.2 75 Yes
208 ornamental Cypress Cupressus spp. 23.6 77 Yes
209 ornamental Cypress Cupressus spp. 18.7 74 Yes
210 ornamental Cypress Cupressus spp. 22.4 75 Yes
211 ornamental Cypress Cupressus spp. 20.0 74 Yes
212 ornamental Cypress Cupressus spp. 24.7 76 Yes
213 ornamental Cypress Cupressus spp. 23.2 70 Yes
214 ornamental Cypress Cupressus spp. 14.8 65 Yes
215 ornamental Cypress Cupressus spp. 9.5 34 Yes
216 ornamental Cypress Cupressus spp. 20.7 70 Yes
216.1 ornamental Cypress Cupressus spp. 10.0 33 Yes
217 ornamental Cypress Cupressus spp. 21.8 64 Yes
218 ornamental Cypress Cupressus spp. 21.3 66 Yes
219 ornamental Cypress Cupressus spp. 24.1 74 Yes
220 ornamental Cypress Cupressus spp. 23.0 76 Yes
221 ornamental Cypress Cupressus spp. 21.1 70 Yes
222 ornamental Cypress Cupressus spp. 10.6 44 Yes
223 ornamental Cypress Cupressus spp. 24.0 77 Yes
224 ornamental Cypress Cupressus spp. 11.8 62 Yes
225 ornamental Cypress Cupressus spp. 14.2 65 Yes
226 Valley oak Quercus lobata 50.7 98 No
227 Oregon white oak Quercus garryana 7.6 34 No
228 Oregon white oak Quercus garryana 6.3 22 No
229 Oregon white oak Quercus garryana 15.0 54 No
230 Oregon white oak Quercus garryana 10.2 52 No
231 Oregon white oak Quercus garryana 8.1 28 No
232 Oregon white oak Quercus garryana 11.0 43 No
233 Oregon white oak Quercus garryana 9.4 36 No
234 Oregon white oak Quercus garryana 13.2 40 No
235 Oregon white oak Quercus garryana 11.5 40 No
236 Oregon white oak Quercus garryana 8.2 43 No
237 Oregon white oak Quercus garryana 16.4 53 No
238 Oregon white oak Quercus garryana 17.8 57 No
239 Oregon white oak Quercus garryana 7.2 35 Yes
240 Oregon white oak Quercus garryana 13.6 48 Yes
241 Oregon white oak Quercus garryana 11.4 41 Yes
242 Oregon white oak Quercus garryana 16.9 59 Yes
243 Oregon white oak Quercus garryana 6.7 33 Yes
244 Oregon white oak Quercus garryana 11.6 54 Yes
245 Oregon white oak Quercus garryana 19.4 51 Yes
246 Oregon white oak Quercus garryana 9.8 46 Yes
247 Oregon white oak Quercus garryana 7.1 31 Yes
248 Oregon white oak Quercus garryana 7.8 51 Yes
249 Oregon white oak Quercus garryana 9.0 62 Yes
250 Oregon white oak Quercus garryana 9.0 43 Yes
251 Oregon white oak Quercus garryana 13.5 52 Yes
252 Oregon white oak Quercus garryana 10.8 57 Yes
253 Oregon white oak Quercus garryana 6.8 44 Yes
254 Oregon white oak Quercus garryana 7.1 40 Yes
255 Oregon white oak Quercus garryana 7.3 40 Yes
256 Oregon white oak Quercus garryana 14.6 46 Yes
257 Oregon white oak Quercus garryana 21.3 57 Yes
258 Oregon white oak Quercus garryana 11.6 54 Yes
259 Oregon white oak Quercus garryana 11.5 51 Yes
260 Oregon white oak Quercus garryana 6.6 42 Yes
261 Oregon white oak Quercus garryana 14.3 58 Yes
262 Oregon white oak Quercus garryana 30.8 75 Yes
263 Oregon white oak Quercus garryana 28.9 59 Yes
264 Oregon white oak Quercus garryana 21.7 54 Yes
265 Oregon white oak Quercus garryana 10.5 55 Yes
266 Oregon white oak Quercus garryana 15.5 54 Yes
267 Oregon white oak Quercus garryana 15.4 65 Yes
268 Oregon white oak Quercus garryana 29.6 53 Yes
269 Oregon white oak Quercus garryana 6.2 34 Yes
270 Oregon white oak Quercus garryana 6.6 37 Yes
271 California black oak Quercus kelloggii 6.4 33 Yes
272 Oregon white oak Quercus garryana 8.2 40 Yes
273 Oregon white oak Quercus garryana 13.5 49 Yes
274 Oregon white oak Quercus garryana 6.7 36 Yes
275 Oregon white oak Quercus garryana 6.1 38 Yes
276 Oregon white oak Quercus garryana 9.0 55 Yes
277 Oregon white oak Quercus garryana 7.9 48 Yes
278 Oregon white oak Quercus garryana 7.1 40 Yes
279 Oregon white oak Quercus garryana 9.5 42 Yes
280 Oregon white oak Quercus garryana 16.9 64 Yes
281 Oregon white oak Quercus garryana 9.3 46 Yes
282 Oregon white oak Quercus garryana 10.3 42 Yes
283 Oregon white oak Quercus garryana 23.6 58 Yes
284 Oregon white oak Quercus garryana 26.4 71 Yes
285 Oregon white oak Quercus garryana 10.2 43 Yes
286 Oregon white oak Quercus garryana 8.1 34 Yes
287 Oregon white oak Quercus garryana 6.2 29 Yes
288 Oregon white oak Quercus garryana 8.8 36 Yes
289 Oregon white oak Quercus garryana 13.2 39 Yes
290 Oregon white oak Quercus garryana 16.1 48 Yes
291 Oregon white oak Quercus garryana 24.7 45 Yes
292 Oregon white oak Quercus garryana 11.3 25 Yes
293 Oregon white oak Quercus garryana 10.8 25 Yes
294 Oregon white oak Quercus garryana 18.5 57 Yes
295 Oregon white oak Quercus garryana 14.1 47 Yes
296 Oregon white oak Quercus garryana 15.2 66 Yes
297 Oregon white oak Quercus garryana 13.3 48 Yes
298 Oregon white oak Quercus garryana 11.6 45 Yes
299 Oregon white oak Quercus garryana 12.0 32 Yes
300 Oregon white oak Quercus garryana 9.1 38 Yes
301 Oregon white oak Quercus garryana 10.3 34 Yes
302 Oregon white oak Quercus garryana 11.6 42 Yes
303 Oregon white oak Quercus garryana 6.4 27 Yes
304 Oregon white oak Quercus garryana 8.2 36 Yes
305 Oregon white oak Quercus garryana 22.6 61 Yes
306 Oregon white oak Quercus garryana 6.6 29 Yes
307 Oregon white oak Quercus garryana 10.7 39 Yes
308 Oregon white oak Quercus garryana 19.1 71 Yes
309 Oregon white oak Quercus garryana 8.6 31 Yes
310 Oregon white oak Quercus garryana 23.0 60 Yes
311 Oregon white oak Quercus garryana 24.7 73 Yes
312 Oregon white oak Quercus garryana 8.3 41 Yes
313 Oregon white oak Quercus garryana 12.6 51 Yes
314 Oregon white oak Quercus garryana 18.0 46 Yes
315 Oregon white oak Quercus garryana 15.2 42 Yes
316 Oregon white oak Quercus garryana 9.0 39 Yes
317 Oregon white oak Quercus garryana 22.4 63 Yes
318 Ponderosa pine Pinus ponderosa 6.1 26 Yes
319 Oregon white oak Quercus garryana 11.2 46 Yes
320 Oregon white oak Quercus garryana 9.1 44 Yes
321 Oregon white oak Quercus garryana 10.7 44 Yes
322 Oregon white oak Quercus garryana 7.3 42 Yes
323 Oregon white oak Quercus garryana 11.3 34 Yes
324 Oregon white oak Quercus garryana 8.1 35 Yes
325 Oregon white oak Quercus garryana 19.6 64 Yes
326 Oregon white oak Quercus garryana 21.5 67 Yes
327 Oregon white oak Quercus garryana 7.2 49 Yes
328 Oregon white oak Quercus garryana 7.2 32 Yes
329 Oregon white oak Quercus garryana 9.4 38 Yes
330 Oregon white oak Quercus garryana 22.3 64 Yes
331 Oregon white oak Quercus garryana 25.2 71 Yes
332 Oregon white oak Quercus garryana 19.8 53 Yes
333 Oregon white oak Quercus garryana 6.2 27 Yes
334 Oregon white oak Quercus garryana 6.3 35 Yes
335 Oregon white oak Quercus garryana 11.4 46 Yes
336 Oregon white oak Quercus garryana 18.0 55 Yes
337 Oregon white oak Quercus garryana 13.2 39 Yes
338 Oregon white oak Quercus garryana 12.2 36 Yes
339 Oregon white oak Quercus garryana 26.4 66 Yes
340 Oregon white oak Quercus garryana 34.0 66 Yes
341 Oregon white oak Quercus garryana 7.7 48 Yes
342 Oregon white oak Quercus garryana 14.5 40 Yes
343 Oregon white oak Quercus garryana 17.6 63 Yes
344 California black oak Quercus kelloggii 6.9 33 Yes
345 Oregon white oak Quercus garryana 7.2 39 Yes
346 Oregon white oak Quercus garryana 15.1 46 Yes
347 Oregon white oak Quercus garryana 8.1 35 Yes
348 Oregon white oak Quercus garryana 6.2 33 Yes
349 Oregon white oak Quercus garryana 6.5 47 Yes
350 Oregon white oak Quercus garryana 39.0 69 Yes
351 Oregon white oak Quercus garryana 11.6 43 Yes
352 Oregon white oak Quercus garryana 9.4 33 Yes
353 Oregon white oak Quercus garryana 6.8 26 Yes
354 Oregon white oak Quercus garryana 9.0 38 Yes
355 Oregon white oak Quercus garryana 15.1 45 Yes
356 Oregon white oak Quercus garryana 19.0 38 Yes
357 Oregon white oak Quercus garryana 6.0 29 Yes
358 Oregon white oak Quercus garryana 6.2 31 Yes
359 Oregon white oak Quercus garryana 9.4 31 Yes
360 Oregon white oak Quercus garryana 24.7 69 Yes
361 Oregon white oak Quercus garryana 28.3 61 Yes
362 Oregon white oak Quercus garryana 10.3 52 Yes
363 Oregon white oak Quercus garryana 17.0 65 Yes
364 Oregon white oak Quercus garryana 13.6 64 Yes
Revised Draft CEQA Initial Study
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025

A P P E N D I X B
P h o t o L o g
Sanhedrin Timber Entitlements
Photo Log
Photos Taken July 27, 2022
Looking east at the existing structure from the entrance of APN 108-040-11.

Looking south toward existing log yard from the entrance of APN 108-040-11.

Looking west at the entrance gate to APN 108-040-11.

Looking north from the northeastern portion of APN 108-040-11 (near entrance gate).

Looking north from the southernmost road of APN 108-040-11 (approximately 440 east from the entrance gate).

Looking east at existing storage tanks from the southernmost road of APN 108-040-11.

Looking southeast at existing storage tanks from the southernmost road of APN 108-040-11.

Looking west toward the entrance gate from the southernmost road of APN 108-040-11.

Looking south towards existing log yard on APN 005-030-42 from southernmost road of APN 108- 040-11.

Looking northeast from the southernmost road of APN 108-040-11.

Looking northeast towards the storage structure from the southernmost road of APN 108-040-11.

Looking northeast toward the storage structure from the eastern end of the northernmost road of APN 108-040-11.

Looking east from the northernmost road of APN 108-040-11.

Looking south from the eastern end of the northernmost road of APN 108-040-11.

Looking west from the northernmost road of APN 108-040-11.

Looking northeast from the northernmost road of APN 108-040-11.

Looking south from the northernmost road of APN 108-040-11 (near the center of the parcel).

Looking east from the northernmost road of APN 108-040-11.

Looking northwest toward the adjacent storage facility from the northernmost road of APN 108- 040-11.

Looking northeast from the northernmost road of APN 108-040-11.

Looking north toward adjacent storage facility from the westernmost road of APN 108-040-11.

Looking south from the westernmost road of APN 108-040-11.

Looking east from the entrance of APN 108-040-18.

Looking southeast from the entrance of APN 108-040-18.

Looking northeast from the entrance of APN 108-040-18.

Looking east from the entrance of APN 108-040-18.

Photos Taken October 06, 2023
Looking east towards the storage units on APN 108-040-11 from railroad tracks.

Looking east towards APN 108-040-011 from railroad tracks.

Looking southwest towards the southeast portion of APN 108-040-11.

Looking north from railroad tracks towards Highway 101. Project Site to the left.

Looking west towards APN 108-040-011 from above.

Revised Draft CEQA Initial Study
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025

A P P E N D I X C
B i o l o g i c a l R e s o u r c e s A s s e s s m e n t Biological Resources Assessment
421 & 23701 North Main Street
Willits, Mendocino County, California
(APN 108-040-11 & 18)
SEPTEMBER 27, 2022
Prepared For:

Sanhedrin Timber Co., LLC.

P.O. Box 249
Weaverville, CA 96093
Prepared By:

Estelle P. Clifton, RPF 2858
Clifton Environmental LLC
PO Box 932
Redwood Valley, CA 95470
(707) 234-1978
Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC ii September 2022

EXECUTIVE SUMMARY
This Biological Resource Assessment Report (BRAR) presents the results of a Biological Resources Assessment (BRA) conducted at the Biological Resource Assessment Area (BRAA) located at 421 & 23701 N. Main Street in Willits, Mendocino County, California. The property is located on Assessor Parcel Numbers (APNs) 108-040-11 & 18, approximately 600 feet north of Willits High School in an industrial area with some commercial and residential use, at the northern edge of the City of Willits.

The property is accessed via a private drive from Main Street and covers 22 acre (Figure 1).

The purpose of this BRA is to document biological studies and perform an analysis of the proposed general plan amendment and rezone (from commercial to heavy industrial), boundary line adjustment, and log yard expansion Project in the City of Willits, in sufficient detail to determine to what extent the proposed Project may affect special-status species and natural resources. Based on information and data collected for the analysis, appropriate mitigation measures, designed to minimize and/or avoid potential biological resource impacts, are provided.

The BRAA is a nearly level former agricultural field, part of which was formerly developed as a Recreational Vehicle (RV) park. There are multiple ditches and some riparian habitats adjoining and within the Project area. Site work associated with the Project will involve vegetation removal, grading, construction of a rocked log yard, reconstruction of watercourse crossings, and several new watercourse crossings between the existing log yard on Casteel Lane, to the south, and the Project to the north. The Project also proposes to fill a ditch between the Project’s two parcels.

The BRAA’s ephemeral and intermittent ditches drain into an unnamed tributary to Mill Creek, east of the BRAA, that is mapped as a Federal Water of the US. As described in Chapter 3, the unnamed tributary to Mill Creek flows under the Highway 101 by-pass and into Mill Creek approximately 0.3 mile north of the Project.

Three special-status plants described in Chapter 4 - Baker’s meadowfoam (Limnanthes bakeri, State Rare/CNPS 1B.1), Davy’s semaphore grass (Plueropogon californicus var. davyi, CNPS 4.3), and North Coast semaphore grass (Plueropogon hooverianus, State Threatened/CNPS 1B.1) - were identified within the Seasonal Wetland habitat at the northern side of the BRAA. Several sensitive natural communities, described in Chapter 4, were identified throughout the BRAA. The Project site provides suitable habitat for nesting birds and special status animal species with potential habitat, described in Chapter 4.

Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC iii September 2022

TABLE OF CONTENTS
Chapter 1. Introduction....................................................................................................................................1

1.1. Project History ............................................................................................................................................1

1.2. Project Description.....................................................................................................................................1 Figure 1 – Vicinity Map...........................................................................................................................................3 Figure 2 – Aerial Image Map...................................................................................................................................4 Chapter 2. Study Methods ...............................................................................................................................5

2.1. Regulatory Requirements...........................................................................................................................5

2.2. Listed and Proposed Species Potentially in the Biological Resource Assessment Area .............................6 Table 1. Regional Species and Habitats of Concern ......................................................................................7

2.3. Studies Required...................................................................................................................................... 17

2.4. Personnel and Survey Dates.................................................................................................................... 17

2.5. Agency Coordination and Professional Contacts .................................................................................... 18

2.6. Limitations That May Influence Results .................................................................................................. 18 Chapter 3. Results: Environmental Setting ................................................................................................... 19

3.1. Description of the Existing Biological and Physical Conditions............................................................... 19

3.1.1. Biological Study Area....................................................................................................................... 19

3.1.2. Physical Conditions.......................................................................................................................... 19

3.1.3. Biological Conditions in the BRAA ................................................................................................... 19 Figure 3 – Biological Resources Map................................................................................................................... 20 Chapter 4. Results: Biological Resources, Discussion of Impacts and Mitigation ......................................... 21

4.1. Natural Communities .............................................................................................................................. 21 Table 2. Mapped Communities ................................................................................................................... 21 Figure 4 – Proposed Project ................................................................................................................................ 23 Figure 5 – Restoration Map................................................................................................................................. 24 Table 3. Project Impact to Sensitive Natural Communities......................................................................... 25

4.1.1. Discussion of Blue Wildrye Prairie................................................................................................... 25

4.1.2. Discussion of Valley Oak Woodland ................................................................................................ 27

4.1.3. Discussion of Valley Oak Riparian Woodland.................................................................................. 28

4.1.4. Discussion of Seasonal Wetland...................................................................................................... 29

4.1.5. Discussion of Ditches 2 - 7............................................................................................................... 30

4.2. Special Status Plant Species..................................................................................................................... 31

4.2.1. Discussion of Baker’s meadowfoam (Limnanthes bakeri)............................................................... 31

4.2.2. Discussion of North Coast Semaphore Grass (Pleuropogon hooverianus)...................................... 32 Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC iv September 2022

4.2.3. Discussion of Davy’s Semaphore Grass (Pleuropogon californicus var. davyi)..................................... 33

4.3. Special Status Animal Species Occurrences ............................................................................................ 33

4.3.1. Discussion White-Tailed Kite (Elanus leucurus)............................................................................... 34

4.3.2. Discussion of Yellow Warbler (Dendroica petechia brewsteri) ....................................................... 35

4.3.3. American Badger (Taxidea taxus).................................................................................................... 36 Chapter 5. Conclusion and Determination.................................................................................................... 38

5.1. Federal Endangered Species Act (FESA) Consultation Summary ............................................................ 38

5.2. California Endangered Species Act Consultation Summary .................................................................... 38

5.3. Wetlands and Other Waters Coordination Summary ............................................................................. 38

5.4. Invasive Species....................................................................................................................................... 38 Chapter 6. References................................................................................................................................... 39 Appendix A Plant and Wildlife Species Observed........................................................................................... 41 Appendix B Photographs ................................................................................................................................ 46 Appendix C Jurisdictional Delineation Report ................................................................................................ 60 Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 1 September 2022
Chapter 1. Introduction
This Biological Resource Assessment Report (BRAR) presents the results of a Biological Resource Assessment (BRA) conducted at the property located at 421 & 23701 N. Main Street in Willits, Mendocino County, California. The property is located on Assessor Parcels 108-040-11 &18, approximately 600 feet north of Willits High School in an area with industrial use and some commercial and residential uses, at the northern edge of the City of Willits.

The purpose of the assessment is to identify special-status plant and wildlife species and sensitive habitats (including wetlands) that have the potential to occur on or in the vicinity of the Biological Resource Assessment Area (BRAA) to determine if the proposed Project could potentially affect these sensitive resources. Based on information and data collected for the analysis, appropriate mitigation measures, designed to minimize and/or avoid potential biological resource impacts, are provided.

1.1. Project History
The Sanhedrin Timber Company proposes to expand their current log storage yard, accessed from Casteel Lane, in the City of Willits, towards the north into two adjoining parcels, also within the city limits. Although the BRAA contains several existing structures, paved, rocked, and seasonal roads, existing watercourse crossings, and various abandoned recreational infrastructure, it remains primarily undeveloped. In the southwestern portion of the site is a building that previously functioned as the RV park office, and in the eastern portion of the site there is an existing storage unit building. Electricity, water, and sewer are currently available at the office building and had previously been distributed to multiple RV sites in the southwestern portion of the site. There is a run‐down tennis court and other small improvement and landscape features associated with the previous RV park in APN 108-040-11.

1.2. Project Description
The Project consists of a general plan amendment and rezone (from commercial to heavy industrial) and boundary line adjustment to facilitate expansion of the existing log yard on Casteel Lane. The proposed Project is accessed via two private drives from N. Main Street in the City of Willits and covers approximately 14-acres of the 22.7-acre BRAA (Figure 1).

Site work associated with the Project will involve vegetation removal and grading for the construction of a rocked log yard, rocked road, watercourse crossings, two ponds, drainage ditches, new plumbing infrastructure, and reconstruction of existing watercourse crossings and drainage ditches.

The Project proposes to retain the office building but demolish the storage unit building. Various other RV infrastructure such as the RV sites, old tennis court, and landscaped areas will be demolished and removed as a part of the grading plan. To ensure adequate water for watering log decks, new wells Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 2 September 2022
have been established that will connect to proposed fire hydrants and ponds. New drainage ditches are proposed to capture log-yard run-off and channel it into the ponds for re-use.

A new road is proposed outside of the rocked log yard near a proposed pond, and two new watercourse crossings are proposed to connect the Casteel Lane log yard with the Project site.

Sanhedrin Timber Company
Vicinity Map
Portions of Sec 7, T18N, R13W, &
Sec. 12, T18N, R14W
Willits USGS 7.5' Quadrangle t
0 1,000 2,000 4,000
Feet
CE LLC 8/31/22
Study Area
FIGURE 1
1360 ft
1400 ft
1440 ft
1480 ft
Ditch 1
Ditch 2
Ditch 6
Ditch 3
Ditch 5
Ditch 4
Ditch 7
Ditch 1
Sanhedrin Timber Company
Orthophoto Map
Portions of Sec 7, T18N, R13W, &
Sec. 12, T18N, R14W
Willits USGS 7.5' Quadrangle
t
0 100 200 400
Feet
2020 NAIP Image
CE LLC 8/31/22
Study Area
Ditch
Main Street
FIGURE 2
Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 5 September 2022
Chapter 2. Study Methods
This BRAR was prepared by Clifton Environmental LLC (CE), Principal Botanist, Estelle P. Clifton with assistance from CE Botany Technician, Paula Gaska. Data on special-status species and habitats known in the area was obtained from state and federal agencies. Maps and aerial photographs of the BRAA and surrounding areas were reviewed. Multiple field surveys were conducted to determine the habitats present. The field surveys, map review, and a review of the biology of evaluated species and habitats were used to determine the special-status species and sensitive habitats that could occur in the BRAA.

Special-status species in this BRA are those listed (or candidate or proposed) under the federal or state endangered species acts, under the California Native Plant Protection Act, as a California species of special concern or fully protected by the Department of Fish and Wildlife (CDFW), or that are on List 1 or 2 of the California Native Plant Society’s Inventory of Rare and Endangered Plants of California (CNPS 2022). Special status natural communities in this review are waters, wetlands, riparian communities, and any natural community ranked S1, S2, S3 on the California Natural Community List (CDFW 2022).

2.1. Regulatory Requirements
The purpose of the BRA is to document biological studies and perform analyses and evaluations necessary to satisfy the legal requirements of state and federal statutes. These statutes include:
• National Environmental Policy Act (NEPA) (42 U.S.C. 4321 et seq.); • Section 404 of the Clean Water Act (33 U.S.C. 1251-1376); • Section 401 Water Quality Certification (33 U.S.C. 1341); • Section 402 of the Clean Water Act (33 U.S.C. 1342)
• Section 10 of the Rivers and Harbors Act (33 U.S.C. 401 et seq.); • Section 1602 of the California Fish and Game Code pertains to streambed alterations; • Federal Endangered Species Act (16 U.S.C. 1531-1543); • Fish and Wildlife Coordination Act (16 U.S.C. 661-666); • National Wild and Scenic Rivers Act (16 U.S.C. 1271-1287); • Executive Order 11990, Protection of Wetlands (May 24, 1977); • California Environmental Quality Act (P.R.C. 21000 et seq.); • California Endangered Species Act (California Fish and Game Code 2050 et seq.); • Native Plant Protection Act (California Fish and Game Code 1900-1913); • California Wild and Scenic Rivers Act (P.R.C. 5093.50 et seq.); • California Porter-Cologne Water Quality Control Act (CA Water Code 13000 et seq.) • Migratory Bird Treaty Act of 1918 (16 U.S.C. 703-711); • Magnuson-Stevens Fishery Conservation and Management Act (as amended through 11 October 1996);
Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 6 September 2022
• Fish and Game Code 3503.5 – Birds of Prey;
• Fish and Game Code 3511, 4700, 5050, 5515 – Fully Protected Species; • Executive Order 13112, Invasive Species (3 February 1999).

2.2. Listed and Proposed Species Potentially in the Biological Resource Assessment Area
Data received from the U.S. Fish and Wildlife Service (USFWS), the California Natural Diversity Database (CNDDB) of the California Department of Fish and Wildlife (CDFW 2022), and the California Native Plant Society (CNPS 2022) program was used to compile a table of regional species and habitats of concern (Table 1). Table 1 provides a general habitat description for each species and a rationale as to why regional species and habitats of concern are either potentially present or absent from the BRAA.

Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 7 September 2022
Table 1. Regional Species and Habitats of Concern
Scientific Name Common Name
Federal
Status a
State
Status a General Habitat Description
Habitat
Present/
Absent c
Rationale
Invertebrates
Bombus caliginosus Obscure bumble
bee
Range includes the west coast of the United
States. Common plants visited by workers include
ceanothus, thistles, peas, lupins, rhododendrons,
Rubus, willows, and clovers.

Absent Limited flowering herbs
available.

Bombus occidentalis Western bumble
bee
Tend to prefer flower-rich meadows of forests
and subalpine zones. Primarily nesting in
underground cavities and in open westsouthwest slopes bordered by trees.

Absent Grassland contains few
flowering herbs.

Danaus plexippus Monarch
butterfly
FC California overwintering population maps include
the California coast range from Mendocino
County south to Baja. Larvae consume milkweed.

Absent Milkweed was not
observed.

Fish
Oncorhynchus kisutch
pop. 4
coho salmon –
southern
Oregon/
northern
California coast
ESU
FT ST Generally, spawn in smaller streams than Chinook
salmon. Spawning sites are typically at the heads
of riffles or tails of pools in loose, silt-free, course gravel with nearby cover for spawning adults.

Juveniles prefer deep, well-shaded pools with
ample overhead cover. Optimal water temps are
40-62°F. Juveniles associated with undercut
banks, logs, and other woody debris for shade
and overhead cover.

Absent While channel
connectivity is present
under the Hwy 101 bypass, habitat is poor as
streams consist of
dredged channels that
are shallow and impacted
by silt. (NMFS 2014).

Amphibians
Rana aurora Northern redlegged frogSSC Inhabits quiet pools of streams, marshes, and occasionally ponds (CDFW 2008)
Absent The BRAA is outside of
the species mapped
range (Gogol-Prokurat
2021).

Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 8 September 2022
Scientific Name Common Name
Federal
Status a
State
Status a General Habitat Description
Habitat
Present/
Absent c
Rationale
Rana boylii foothill yellowlegged frogSSC Found in/near quiet permanent water of rocky streams, marshes, or ponds; damp woods/
meadows with rocky substrate. Occurs in
woodland and forested sites with dense
vegetation, close to water, some shading; and
ephemeral pools if wet until late spring/early
summer. Breeds in permanent water; eggs
attached to emergent vegetation. Disperses from
water in wet weather. Estivates in small burrows,
leaf litter, moist sites near riparian areas. Egg
clusters attached to gravel or rocks in moving
water near stream margins. Mating & egg-laying
in streams & rivers (not ponds or lakes), Aprilearly July, after streams slow from winter runoff.

Absent The brackish muddy
ditches near the Project
do not provide suitable
habitat for the species.

Taricha rivularis red-bellied newt SSC Adults are terrestrial, becoming aquatic when breeding. Adults emerge after a few fall rains
and feed for a period before migrating to their
breeding stream. Activity typically occurs at night
and in the late afternoon, but newts are also
found active in streams and on the surface in
daylight during the breeding season and during
rains. They spend the dry summer in moist
habitats under woody debris, rocks, in animal
burrows. Juveniles apparently spend most of
their time underground and are not active on the
surface until near sexual maturity. Reproduction
is aquatic. Clean, rocky streams and rocky rivers
with moderate to fast flow. Ponds, lakes, and
other standing waters are avoided. Breeding
takes place from late February to May, peaking in
March.

Absent The streams near the
Project are not
considered suitable
habitat for the species.

Reptiles
Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 9 September 2022
Scientific Name Common Name
Federal
Status a
State
Status a General Habitat Description
Habitat
Present/
Absent c
Rationale
Emys marmorata western pond
turtle
SSC Habitats, with permanent or nearly permanent
water with abundant vegetation. Omnivorous,
feed on aquatic plants, invertebrates, fish, frogs.

Require basking sites, such as partially
submerged logs, rocks, floating vegetation.

Hibernation in colder areas is underwater in mud.

Two habitats for oviposition: Along large slowmoving streams, eggs are deposited in sandy banks. Along foothill streams, suitable nest sites
may be up hillsides in sandy to very hard soils.

Soils need fairly high humidity. Basking sites
required. Mating in April-May
Absent Habitat is not suitable
with seasonal hydrology.

Birds
Agelaius tricolor tricolored
blackbird
ST Mostly a resident in CA; common in Central
Valley and coastal areas from Sonoma Co.
south. Highly colonial. Breeds near fresh water, in
emergent wetlands with tall, dense cattails or
tules; also in willow, blackberry, & wild rose
thickets. Feed in grasslands/croplands, mostly on
insects & spiders.

Absent Limited thickets and at
the margin of range.

Accipiter gentilis northern
goshawk
SSC Uses dense, mature conifer and deciduous
forests, interspersed with meadows, openings,
and riparian areas.

Absent Habitat is too
fragmented and near
development.

Accipiter striatus sharp-shinned
hawk
WL Ponderosa pine, black oak, riparian deciduous,
mixed conifer, and Jeffrey pine habitats. Prefers
riparian areas. North-facing slopes with plucking
perches are critical requirements. Nests usually
within 275 feet of water.

Absent Habitat is too
fragmented and near
development.

Charadrius nivosus ssp.
nivosus
western snowy
plover
FT Coastal beaches in Mendocino and Sonoma
Counties.

Absent Habitat is absent.

Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 10 September 2022
Scientific Name Common Name
Federal
Status a
State
Status a General Habitat Description
Habitat
Present/
Absent c
Rationale
Coccyzus americanus
occidentalis
western yellowbilled cuckooFT CE Uncommon to rare summer resident of valley foothill and desert riparian habitats in scattered
locations in CA. Extensive riparian thickets, esp.
w/ mature willows, dense understory foliage,
near slow-moving watercourses.

Absent The riparian thicket
located on and near the
Study Area are not
substantial in size.

Elanus leucurus white-tailed kite FP Open grasslands, meadows, marshes, foothills and valley margins adjacent to deciduous
woodlands in CA lowlands west of the Sierra
Nevada range. Nest of loosely piled sticks/twigs,
placed near top of dense oak, willow, or other
tree stand near open foraging area. Prey mostly
voles, small mammals. Rarely found away from
agricultural areas and restricted to lower
elevations. Nest-building occurs January through
August; non-migratory.

Present Both nesting and hunting
habitat present. A pair
was observed at the
northeastern edge of the
BRAA.

Icteria virens yellow-breasted
chat
SSC Frequents dense, brushy thickets and tangles
near water, and thick understory in riparian
woodland. Requires riparian thickets of willow
and other brushy tangles near watercourses for
cover.

Absent The riparian habitat on
and adjoining the BRAA
are considered too
sparse.

Progne subis purple martin SSC Rare summer resident in N.CA. Found in valley foothill, montane hardwood, hardwood-conifer,
and riparian habitats. Breeding habitat is oldgrowth, multi-layered open forests and woodlands with snags. Feed on insects, hawked
in flight.

Absent Conifers and old-growth
are not present.

Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 11 September 2022
Scientific Name Common Name
Federal
Status a
State
Status a General Habitat Description
Habitat
Present/
Absent c
Rationale
Setophaga petechia yellow warbler SSC Frequents open to medium-density woodlands and forests with a heavy brush understory
(during the breeding period). Habitat during the
breeding season is found in deciduous riparian
areas with cottonwoods, alder, willow and other
miscellaneous small trees and shrubs.

Present Nesting and foraging
habitat is present.

Strix occidentalis
caurina
Northern
Spotted Owl
FT,
BLM,
USFS
ST, CDF Mature multi-layered mixed conifer, redwood
and Douglas fir forests with a permanent water
source and suitable nesting sites. Prey mostly on
small mammals. Nests in cavities or broken tops
of large trees or snags. Breeds February to June.

Absent Approximately 50-acres
of suitable foraging
habitat appears to be
present within 0.7 miles
from the BRAA. The
nearest Activity Centers
are mapped 2 miles
north of the BRAA and 3
miles west of the BRAA.

Mammals
Arborimus pomo Sonoma tree vole SSC Prefers mature and other stands of Douglas fir, redwood, or mixed evergreen trees in fog belt
Specializes on needles of Douglas fir and grand
fir. Nests of Douglas fir needles are constructed in
trees, preferably tall trees.

Absent While in the range of this
species, conifer forest is
not present.

Corynorhinus
townsendi
Townsend's bigeared batSSC Prefers mesic habitats with caves, mines, tunnels and buildings for roosting and cover. May use
separate sites for night, day, hibernation, or
maternity roosts. Roosting sites are the most
critical limiting factor.

Absent Roosting habitat is
absent.

Martes caurina
humboldtensis
Humboldt
marten
FT SE Occurs only in the coastal redwood zone from
Oregon border south to Sonoma County.

Associated with late-successional coniferous
forests, prefer forests with low, overhead cover.

Absent Coniferous forest is
absent.

Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 12 September 2022
Scientific Name Common Name
Federal
Status a
State
Status a General Habitat Description
Habitat
Present/
Absent c
Rationale
Pekania pennanti fisher Preferred habitat includes mid- to late-seral stages of conifer development and deciduousriparian. High degrees of canopy cover are also preferred. Cavities in large trees, snags and logs,
rocky areas and logging slash provide suitable
cover. Fisher are active yearlong.

Absent While in the range of the
species, large areas of
mature dense conifer
forest do not extend into
Little Lake Valley floor.

Taxidea taxus American badger SSC Grasslands, savannas, and mountain meadows near timberline are preferred. Badgers prey
primarily on burrowing rodents. Sufficient food,
friable soils, and relatively open, uncultivated
ground. Mating occurs in late summer or early
autumn, followed by delayed implantation
Present While there is a low
likelihood of the species
occurring, it is found
statewide except for
humid coastal forests of
Del Norte and portion of
Humboldt Co.

Plants /CNPS b
Alisma gramineum narrow-leaved
water-plantain
/2B.2 Perennial rhizomatous herb (aquatic) found in
marshes and swamps (shallow freshwater) from
1280 to 5905 feet. Blooms June to August (CNPS
2022).

Present Although not observed,
suitable habitat is
present.

Anisocarpus scabridus scabrid alpine
tarplant
/1B.3 Perennial herb found in upper montane
coniferous forest (metamorphic, rocky) from
5415 to 7545 feet. Blooms July to August
(September) (CNPS 2022).

Absent Coniferous forest absent
Astragalus agnicidus Humboldt Count
milk-vetch
SE
/1B.1
Perennial herb found in broadleaf upland forest,
North Coast coniferous forest, disturbed areas,
openings, sometimes roadsides from 395 to 2625
feet. Blooms April to September (CNPS 2022).

Absent BRAA is outside known
range.

Blennosperma bakeri Sonoma sunshine FE SE/1B.1 Annual herb found in valley and foothill grassland (mesic) and vernal pools from 35 to 360 feet.

Blooms March to May (CNPS 2022).

Absent BRAA is outside the
elevation range.

Brasenia schreberi watershield /2B.3 Perennial rhizomatous herb (aquatic) found in marshes and swamps (freshwater) from 0 to 7220
feet. Blooms June to September (CNPS 2022).

Absent Suitable marsh not found
within the BRAA.

Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 13 September 2022
Scientific Name Common Name
Federal
Status a
State
Status a General Habitat Description
Habitat
Present/
Absent c
Rationale
Bruchia bolanderi
Bolander’s
bruchia
/4.2 Moss found in lower montane coniferous forest,
meadows and seeps, upper montane coniferous
forest, in damp soil from 5580 to 9185 feet (CNPS
2022).

Absent Habitat and elevation
range not suitable.

Calystegia collina ssp.
tridactylosa
three-fingered
morning glory
/1B.2 Perennial rhizomatous herb found in chaparral,
cismontane woodland; gravelly, openings, rocky
and serpentinite from 0 to 1970 feet. Blooms
April to June (CNPS 2022).

Absent Serpentine and chaparral
habitats are absent.

Ceanothus gloriosus
var. exaltatus
glory brush /4.3 Perennial evergreen shrub found in chaparral from 100 to 2000 feet. Blooms March to June
(August) (CNPS 2022).

Absent Chaparral habitat is
absent.

Cryptantha dissita serpentine
cryptantha
/1B.2 Annual herb found in chaparral (serpentinite)
from 1295 to 1905 feet. Blooms April to June
(CNPS 2022).

Absent Serpentine and chaparral
habitats are absent.

Cryptantha excavata deep-scarred
cryptantha
/1B.1 Annual herb found in cismontane woodland
(gravelly, sandy) from 330 to 1640 feet. Blooms
April to May (CNPS 2022).

Absent Gravely sandy habitat is
absent.

Fritillaria roderickii Roderick’s
fritillary
SE
/1B.1
Perennial bulbiferous herb; found in coastal bluff
scrub, coastal prairie, valley and foothill grassland
from 50 to 1310 feet. Blooms March to May
(CNPS 2022).

Present Although not observed,
suitable habitat is
present.

Gilia capitata ssp.
pacifica
Pacific gilia /1B.2 Annual herb found in coastal bluff scrub, coastal prairie, chaparral (openings), and valley and
foothill grassland from 15 to 5465 feet. Blooms
from April to August (CNPS 2022).

Present Although not observed,
suitable habitat is
present.

Hemizonia congesta
ssp. calyculata
Mendocino
tarplant
/4.3 Annual herb found in cismontane woodland,
valley and foothill grassland, usually serpentinite
from 740 to 4595 feet. Blooms July to November
(CNPS 2022).

Absent Serpentine habitat is not
present.

Hesperolinon
adenophyllum
glandular
western flax
/1B.2 Annual herb found in chaparral, cismontane
woodland, valley and foothill grassland, usually
serpentinite from 490 to 4315 feet. Blooms May
to August (CNPS 2022).

Absent Serpentine habitat is not
present.

Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 14 September 2022
Scientific Name Common Name
Federal
Status a
State
Status a General Habitat Description
Habitat
Present/
Absent c
Rationale
Horkelia tenuiloba thin-lobed
horkelia
/1B.2 Perennial herb found in broadleafed upland
forest, chaparral, valley and foothill grassland;
mesic, openings, sandy from 165 to 1640 feet.

Blooms May to July (August) (CNPS 2022).

Absent Soils not suitable.

Lasthenia burkei Burke’s goldfields FE SE
/1B.1
Annual herb found in meadows and seeps
(mesic), vernal pools from 50 - 1970 feet. Blooms
April to June (CNPS 2022).

Present Mesic grassland habitat is
present.

Lasthenia conjugens Contra Costa
goldfields
FE /1B.1 Annual herb found in cismontane woodland,
playas (alkaline), valley and foothill grassland, and
vernal pools; mesic from 0 to 1540 feet. Blooms
March to June (CNPS 2022).

Present Mesic grassland habitat is
present.

Leptosiphon acicularis bristly
leptosiphon
/4.2 Annual herb found in chaparral, cismontane
woodland, coastal prairie, valley and foothill
grassland from 180 to 4920 feet. Blooms April to
July (CNPS 2022).

Present Mesic grassland habitat is
present.

Limnanthes bakeri Baker’s
meadowfoam
SR
/1B.1
Annual herb found in meadows and seeps,
marshes and swamps (freshwater), valley and
foothill grassland (vernally mesic), and vernal
pools from 575 to 2985 feet. Blooms April to May
(CNPS 2022).

Present Mesic grassland habitat is
present. Species was
found within the BRAA.

Lupinus milo-bakeri Milo Baker’s
lupine
SCT
/1B.1
Annual herb found in cismontane woodland
(often roadsides), valley and foothill grassland
from 1295 to 1410 feet. Blooms June to
September (CNPS 2022).

Present Suitable grassland
habitat is present.

Navarretia
leucocephala ssp.
bakeri
Baker’s
navarretia
/1B.1 Annual herb found in cismontane woodland,
lower montane coniferous forest, meadows and
seeps, valley and foothill grassland, and vernal
pools, mesic from 15 to 5710 feet. Blooms April
to July (CNPS 2022).

Present Mesic grassland habitat is
present.

Perideridia gairdneri
ssp. gairdneri
Gairdner’s
yampah
/4.2 Perennial herb found in broadleafed upland
forest, chaparral, coastal prairie, valley and
foothill grassland, vernal pools, vernally mesic
from 0 to 2000 feet. Blooms June to October
(CNPS 2022).

Present Mesic grassland habitat is
present.

Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 15 September 2022
Scientific Name Common Name
Federal
Status a
State
Status a General Habitat Description
Habitat
Present/
Absent c
Rationale
Piperia candida white-flowered
rein orchid
/1B.2 Perennial herb found in broadleafed upland
forest, lower montane coniferous forest, and
North Coast coniferous forest from 100 to 4300
feet. Blooms (March) May to September (CNPS
2022).

Absent Habitat not within the
BRAA.

Plagiobothrys
lithocaryus
Mayacamas
popcornflower
/1A Annual herb found in chaparral, cismontane
woodland, valley and foothill grassland, mesic
from 985 to 1475 feet. Blooms April to May
(CNPS 2022).

Present Mesic grassland habitat is
present.

Pleuropogon
californicus var. davyi
Davy’s
semaphore grass
/4.3 Perennial rhizomatous herb found in cismontane
woodland, lower montane coniferous forest,
meadows and seeps from 490 to 2000 feet.

Blooms March to June (CNPS 2022).

Present Mesic grassland habitat is
present. Species was
found within the BRAA.

Pleuropogon
hooverianus
North Coast
semaphore grass
ST/1B.1 Perennial rhizomatous herb found in broadleafed upland forest, meadows and seeps, North Coast
coniferous forest; open areas, mesic from 35 to
2200 feet. Blooms April to June (CNPS 2022).

Present Mesic grassland habitat is
present. Species was
found within the BRAA.

Potamogeton
epihydrus
Nuttall’s ribbonleaved
pondweed
/2B.2 Perennial rhizomatous herb (aquatic) found in
marshes and swamps (shallow freshwater) from
1210 to 7125 feet. Blooms (June) July to
September (CNPS 2022).

Absent Suitable marsh habitat is
not present.

Ramalina thrausta angel’s hair
lichen
/2B.1 Fruticose lichen (epiphytic) found in North Coast coniferous forest; on dead twigs and other
lichens from 245 to 1410 feet (CNPS 2022).

Absent Forest habitat is not
present.

Silene bolanderi Bolander’s
catchfly
/1B.2 Perennial herb found in chaparral (edges),
cismontane woodland, lower montane coniferous
forest, meadows and seeps from 1380 to 3775
feet. Blooms May to June (CNPS 2022).

Absent Forested montane
habitat is absent.

Silene hookeri Hooker’s catchfly /2B.2 Perennial herb found in chaparral, cismontane woodland, lower montane coniferous forest,
often in grassy openings, sometimes on rocky
slopes, often openings, sometimes rocky,
sometimes serpentinite from 490 to 4135 feet.

Blooms (March) May to July (CNPS 2022).

Absent Forested montane
habitat is absent.

Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 16 September 2022
Scientific Name Common Name
Federal
Status a
State
Status a General Habitat Description
Habitat
Present/
Absent c
Rationale
Trifolium amoenum two-fork clover FE /1B.1 Annual herb found in coastal bluff scrub, valley and foothill grassland (sometimes serpentinite)
from 15 to 1360 feet. Blooms April to June (CNPS
2022).

Present The BRAA meadow
habitat may be suitable.

Trifolium
buckwestiorum
Santa Cruz clover /1B.1 Annual herb found in broadleafed upland forest, cismontane woodland, coastal prairie, gravelly,
margins from 345 to 2000 feet. Blooms April to
October (CNPS 2022).

Absent The BRAA meadow soils
are not believed to be
suitable.

Trifolium hydrophilum Saline clover /1B.2 Annual herb found in marshes and swamps, valley and foothill grassland (mesic, alkaline),
vernal pools from 0 to 985 feet. Blooms April to
June (CNPS 2022).

Present Mesic grassland habitat is
present.

Wyethia longicaulis Humboldt
County wyethia
/4.3 Perennial herb found in broadleafed upland
forest, coastal prairie, lower montane coniferous
forest, sometimes roadsides from 2460 to 5005
feet. Blooms May to July (CNPS 2022).

Absent BRAA is out of the known
range of this species.
a Status: Federal Endangered (FE); Federal Threatened (FT); Federal Proposed (FP); Federal Candidate (FC); Federal Delisted (FD); USFS Sensitive (S); USFS Watch list (WL); State Endangered (SE); State Threatened (ST); State Candidate Endangered (SCE); State Candidate Threatened (SCT); Fully Protected (FP); State Rare (SR); State Species of Special Concern (SSC); Species of Local Concern (SLC); Proposed Critical Habitat (PCH); Critical Habitat (FCH) - Project footprint is located within a designated critical habitat unit, but does not necessarily mean that appropriate habitat is present.
b CNPS List. 1A = Presumed Extinct in CA; 1B = Rare or Endangered in CA and elsewhere; 2 = R/E in CA and more common elsewhere; 3 = More information is needed about this plant species (review list); 4 = Limited distribution (watch list) CNPS List Decimal Extensions: .1 = Seriously endangered in California (over 80% of occurrences threatened / high degree and immediacy of threat); .2 = Fairly endangered in California (20-80% occurrences threatened); .3 = Not very endangered in California (<20% of occurrences threatened or no current threats known). c Absent = No habitat present and no further work needed. Present = habitat is, or may be present.

Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 17 September 2022

2.3. Studies Required
A list from the U.S. Fish and Wildlife Service (USFWS), Critical Habitat Portal, was obtained in 2020 and updated on April 22, 2022 (USFWS 2022). The list identified federal-listed, candidate, or proposed species that potentially occur in or could be affected by the Project. The CNDDB and CNPS online searches were queried for the Willits 7.5’ USGS quad and the eight surrounding quads to determine likely and known occurrences of special-status species on or near the BRAA (CDFW 2022 & CNPS 2022).

Data received from USFWS, CNDDB, and CNPS records were used to compile a table of regional species and habitats of concern (Table 1). Field surveys were based on the Protocols for Surveying and Evaluation Impacts to Special Status Native Plant Populations and Sensitive Natural Communities (CDFW 2018) and consisted of walking through the BRAA to determine if any special-status species or their habitat were present. Plant species located during the surveys were identified to the lowest taxonomic level necessary to determine presence or absence of special status plants (Appendix A). The Jepson Flora Project (Jepson 2022) was consulted to determine the taxonomic nomenclature. A Manual of California Vegetation (CNPS 2022) was used to classify and describe the representative natural plant communities present (see photos in Appendix B). The California Natural Community List (CDFW 2022) was consulted for additional information on current ranking of described communities and their associations.

A Jurisdictional Delineation Report of waters of the U.S., including wetlands, was prepared to identify jurisdictional features regulated under Section 404 of the Clean Water Act (Appendix C). The purpose of the survey was to delineate all wetlands and waters of the U.S. within the BRAA.

Waters of the United States require U.S. Army Corps of Engineers (ACOE) authorization under Section 404 of the Clean Water Act (33 U.S.C. 1344) and Clean Water Act Section 401 authorization from the Regional Water Quality Control Board (RWQCB). Waters of the United States generally include tidal waters, lakes, ponds, rivers, streams (including intermittent streams), wetlands (excluding isolated wetlands for the ACOE), and farmed wetlands. Waters of the United States are defined in EPA, 33 CFR § 328.3 and include “other waters” such as intrastate lakes, rivers, streams, and wetlands; tributaries to above waters; and wetlands adjacent to waters. Jurisdiction in non-tidal areas extends to the ordinary high-water mark (OHWM). Initial delineation surveys were timed approximately two-weeks after a sizable rain event when prolonged inundation and primary indicators of wetland hydrology could best be observed. A summary of potential jurisdictional features can be found in the Jurisdictional Delineation Report (Appendix C, Table 2).

2.4. Personnel and Survey Dates
Fieldwork for the BRA was led by Estelle P. Clifton of Clifton Environmental (CE LLC) with assistance from botanists Heather Morrison (Salix Natural Resource Consulting), and botany technicians Paula Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 18 September 2022
Gaska (CE LLC), Ernest Simanungkalit (NCRM, Inc.), and Lexi Smith (NCRM, Inc.), and wildlife biologist Annalise Smith (NCRM, Inc.) between July 2020 and May 2022. Botanical surveys were conducted 16 April, 22 May, 6 June 2021, and 31 May, 7 May, and 13 May 2022. A routine-level preliminary wetland delineation (Appendix C) of the Study Area was conducted on 3 April 2021, 30 April, 5 May, 7 May, 10 May, and 13 May 2022 by Estelle Clifton.

2.5. Agency Coordination and Professional Contacts
Coordination occurred with Russell Dorvall of Sanhedrin Timber Company and Rebecca Dalske, Senior Planner with LACO Associates. Dusty Duley, City of Willits Planning Director, advised on environmental feedback received during a previous development application on a portion of the site, including comments received from CDFW in 2021 on the previous development proposal. Repeated attempts to contact the Arcata and Sacramento USFWS offices were unsuccessful in the spring of 2022.

2.6. Limitations That May Influence Results
There were no limitations that may influence results.

Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 19 September 2022
Chapter 3. Results: Environmental Setting
The BRAA is on the North Coast, Coastal Range at the margin of Little Lake Valley at the northern end of the City of Willits.

3.1. Description of the Existing Biological and Physical Conditions

3.1.1. Biological Study Area
The BRAA includes the two parcels where the Project is proposed to be constructed. The BRAA also includes two proposed stream crossings connecting the Project to the existing log yard located south of Project.

3.1.2. Physical Conditions
The BRAA is located on the Willits USGS topographic quad (Section 7, T18N, R13W and Section 12, T18N, R14W, MDB&M), see Figure 1, and is in the Eel River hydrologic unit (hydrologic unit code 11116101). The elevation of the BRAA is approximately 1,360 feet above sea level. Valley foothill is located west of the BRAA. Otherwise, the surrounding is level valley floor.

While some undisturbed natural communities are present, considerable anthropogenic disturbance has occurred in the BRAA as evidenced by recreational buildings and structures, paved, rocked, and seasonal roads, disturbance vegetation, berms near drainages, and the numerous ditch structures present.

3.1.3. Biological Conditions in the BRAA
Natural Communities are defined by species composition and relative abundance. The biological communities in the BRAA are meadow, wet meadow (wetlands), oak woodland, and ephemeral and intermittent streams/ditches. The biological communities are mapped on Figure 3. Existing roads, structures, and other developed areas are also mapped.

Main St
Elymus glaucus
Pleuropogon hooverianus Limnanthes bakeri Rosa Californica Plueropogon
californica var. dayvi
Elymus glaucus
Sec 7
T18N R13W
Sec 12
T18N R14W
Sec 18
T18N R13W
Sec 13
T18N R14W CE LLC 9/26/22
Sanhedrin Timber Company
Biological Resources Map
Portions of Sec 7, T18N, R13W, &
Sec. 12, T18N, R14W
Willits USGS 7.5' Quadrangle t
0 100 200
Feet
Study Area
Rare plant or community
Plant Community
Blackberry Scrub
Developed
Disturbed/Fill
Landscaped
Meadow
Oak Woodland
Riparian Woodland
Water/Ditch
Wet Meadow
Ditch
Main Street
FIGURE 3
Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 21 September 2022
Chapter 4. Results: Biological Resources,
Discussion of Impacts and Mitigation
The following sections discuss special status wildlife species with potential habitat, identified plant species, identified plant communities, wetlands and waters potentially subject to CWA jurisdiction, and impacts to natural communities and plants of special concern in the BRAA.

4.1. Natural Communities
As provided in Table 2 below, the BRAA contains the following identified plant communities and vegetation alliances correlated with California Natural Community List (CDFW) and A Manual California Vegetation (CNPS).

Table 2. Mapped Communities
Mapped Community Type Acreage Natural Community /Alliance name; rarity rank1 Meadow & Wet
Meadow/Wetland

7.75 Poa pratensis Herbaceous Semi-Natural Alliance; GNA/SNA Blue wildrye prairie - Elymus glaucus Montane Herbaceous Alliance; S3?, G3?
Danthonia californica Herbaceous Alliance; S4, GNR
Phalaris aquatica Herbaceous Alliance; SNA, GNA
California rose briar patches - Rosa californica Shrubland Alliance; S3, G3
Holcus lanatus Herbaceous Semi-Natural Alliance; SNA, GNA Festuca arundinacea Provisional Semi-Natural Alliance; GNA SNA
Oak Woodland

1.26 Quercus (kellogii, lobata) Woodland Alliance; S4, G4 Valley oak woodland - Quercus lobata Woodland Alliance; S3, G3
Riparian Woodland

1.96 Salix lasiolepis Shrubland Alliance; S4, G4
Valley oak riparian woodland - Quercus lobata Riparian
Woodland Alliance; S3, G3
Ditch/Water

0.39 Juncus mexicanus Herbaceous Alliance; G5, S4
Juncus effusus Herbaceous Alliance; S4?, G4
Salix lasiolepis Shrubland Alliance; S4, G4
Other
Landscaped Woodland 2 3.51 Populus alba semi-natural stand 1 CDFW (2021) considers a community with a global rank of G1, G2, or G3 or a state rank of S1, S2, or S3 to be of concern and included in CNDDB. Sensitive natural communities of concern are displayed in bold font. 2 Not correlated to Manual of California Vegetation or other published community type.

Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 22 September 2022
Mapped Community Type Acreage Natural Community /Alliance name; rarity rank1 Populus sp. - Acer sp. cultivar stand
Disturbed/Fill Scrub

4.51 Conium maculatum Herbaceous Semi-Natural Alliance;

GNA/SNA
Baccharis pilularis Shrubland Alliance; G5/S5
Rubus armeniacus Shrubland Semi-Natural Alliance; GNR/SNR Bromus diandrus – Avena spp. Alliance; GNA, SNA
Paved/Disturbed/Barren 2.46 Ruderal
Total 21.84
The most prominent biological community in the BRAA is Meadow. Of the 7.75 acres of the Meadow community, 0.97-acre were identified as Wet Meadow/Seasonal Wetland, which is a sensitive natural community (described in Section 4.1, below). Several populations of sensitive natural community Blue Wildrye Prairie are located in the Meadow. Other sensitive natural communities within the BRAA, including Valley Oak Woodland, Wet Meadow, and ephemeral and intermittent Ditches/Streams, discussed below.

A portion of the BRAA contains previously disturbed habits that appears to be on imported fill. The Disturbed/Fill habitat is dominated by non-native poison hemlock (Conium maculatum), coyote brush (Baccharis pilularis), and non-native Himalayan blackberry (Rubus armeniacus). This habitat occurs in multiple locations across the BRAA.

The Landscaped Woodland occupies 3.52 acres within the BRAA and sits in the southern half of the site where the previous RV park operated. Species that dominate this community include a semi-natural stand of white poplar (Populus alba), some of which has spread into the riparian woodland community, and cultivated poplar (Populus sp.), non-native maple (Acer sp.), and other cultivar trees.

Table 3 estimates the acreage of each natural community that will be affected by the Project based on preliminary designs, as shown on Figure 4.

Sec 7
T18N R13W Sec 12
T18N R14W
Sec 18
T18N R13W
Sec 13
T18N R14W
CE LLC 9/27/22
Sanhedrin Timber Company
Proposed Project Map
Portions of Sec 7, T18N, R13W, &
Sec. 12, T18N, R14W
Willits USGS 7.5' Quadrangle t
0 100 200
Feet
Main Street
Study Area
Project Feature
log decks
pond
new ditch
pvc
road
well pipe
Plant Community
Blackberry Scrub
Developed
Disturbed/Fill
Landscaped
Meadow
Oak Woodland
Riparian Woodland
Water
Wet Meadow
Ditch
Impact Area
Temporary Impact
Permanent Impact
FIGURE 4
Sec 7
T18N R13W Sec 12
T18N R14W
Sec 18
T18N R13W
Sec 13
T18N R14W
CE LLC 9/27/22
1:1,800
Main Street
Study Area
Planting Area
Project Feature
log decks
pond
new ditch
pvc
road
well pipe
Plant Community
Blackberry Scrub
Developed
Disturbed/Fill
Landscaped
Meadow
Oak Woodland
Riparian Woodland
Water
Wet Meadow
Ditch
Sanhedrin Timber Company
Restorarion Map
Portions of Sec 7, T18N, R13W, &
Sec. 12, T18N, R14W
Willits USGS 7.5' Quadrangle
t
0 100 200
Feet
FIGURE 5
Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 25 September 2022
Table 3. Project Impact to Sensitive Natural Communities Natural Community Acreage
Temporary
Impact (ac)
Permanent
Impact (ac)
Blue wildrye prairie 0.18 -- 0.1
Valley oak woodland 1.26 0.14 0.04
Valley oak riparian woodland 1.96 0.02 0.15
Ditch 2 0.14 0.003 0.01
Ditch 3 0.05 -- 0.01
Ditch 4 0.04 -- 0.04
Ditch 5 0.06 -- 0.001
Ditch 6 0.09 0.001 --
Ditch 7 0.01 0.001 0.003
Wetland 1 – 5 (wet meadow) 0.97 0.01 0.02
Total 0.18 0.37
Additionally, of the other (non-sensitive communities), approximately 4.82 acres of Meadow are proposed to be permanently impacted and 0.80 acre temporarily impacted by the Project.

Approximately 2.97 acres are of Landscaped Woodland is proposed to be permanently impacted and

0.08 acre temporarily impacted by the Project. The following sections describe the natural communities of special concern that are present on-site and the potential project impacts to these communities.

4.1.1. Discussion of Blue Wildrye Prairie

4.1.1.1. SURVEY RESULTS
The Meadow and Wet Meadow plant community runs throughout the length of the BRAA, from a large field in the southeastern portion of the site, through the center of the project, and to the road along the site’s northern border. The Meadow community is dominated by Kentucky blue grass (Poa pratensis), fescue (Festuca spp.), harding grass (Phalaris aquatica), Timothy grass (Phleum pratense), blue wildrye (Elymus glaucus spp. glaucus), meadow foxtail (Alopecurus pratensis), and velvet grass (Holcus lanatum). Within the Meadow community are several areas correlated to the Blue Wildrye Prairie community, considered a natural community of special concern by CDFW with the qualifier “?,” identifying this community rank as inexact or uncertain.

4.1.1.2. AVOIDANCE AND MINIMIZATION EFFORTS
Blue Wildrye Prairie cannot be avoided during construction of a proposed water storage pond and a water pipeline. It occurs in three patches, two of which are within the Meadow habitat where a water storage pond is proposed. A third area is within the eastern most Valley Oak Woodland. Temporary impact could occur to the Blue Wildrye Prairie located within the Valley Oak Woodland. Minimization efforts will include marking the limits of construction with temporary fencing. Incorporation of this Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 26 September 2022
mitigation measure will ensure that construction is limited to the Project area to avoid the potential for impacts to Blue Wildrye Prairie beyond those permitted by construction entitlements.

4.1.1.3. PROJECT IMPACTS
Impacts to the Blue Wildrye Prairie include construction of the proposed northern water storage pond and a water pipeline along the northeastern portion of the BRAA. The Project will result in the permanent loss of 0.10 acre of Blue Wildrye Prairie in the BRAA (Figure 4).

4.1.1.4. COMPENSATORY MITIGATION
The project proposes to revegetate areas of temporary disturbance within the Project footprint with native vegetation, including blue wildrye (Elymus glaucus) seed. Revegetation of temporarily disturbed areas will total approximately 0.26 acre for a compensatory mitigation ratio of 2.6:1. Planting areas are shown on Figure 5.

Commercially available native grasses will be used to revegetate. These grasses include but are not limited to:
• Blue wildrye (Elymus glaucus)
• California brome (Bromus sitchensis var. carinatus)
• California fescue (Festuca californica)
• Pine bluegrass (Poa secunda)
• California oatgrass (Danthonia californica)
A native grass seed blend such as Holdfast Native Blend from LeBallister’s can be purchased and used as a viable option for revegetation plans. This mix consists of California brome, blue wild rye, three weeks fescue (Festuca microstachys), California poppy (Eschscholzia californica), and California native lupines (Lupinus spp.) (LeBallister’s 2022). This seed mix conforms to the standard practice of using grasses, legumes, and wildflowers in combination for erosion control and revegetation plans.

A qualified botanist or landscape architect will advise the field crew on seeding rate and dispersal technique. Broadcast seeding is an effective way to reclaim bare areas and should be done just prior to the autumn rains. If insufficient rain is in the forecast when seeding can occur, irrigation must be used to gently water in the seeds.

4.1.1.5. CUMULATIVE EFFECTS
With implementation of the native grass revegetation measures, the Project will not result in adverse cumulative impacts to Blue Wildrye Prairie.

Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 27 September 2022

4.1.2. Discussion of Valley Oak Woodland

4.1.2.1. SURVEY RESULTS

1.26 acres of Valley Oak Woodland are mapped within the BRAA. While Valley Oak Woodland is a common natural community in the Little Lake Valley, it is considered a natural community of special concern by CDFW. Valley Oak Woodland is primarily located in the northeast portion of the BRAA where a pipeline is proposed by the Project. This plant community is dominated by valley oak (Quercus lobata) and black oak (Quercus kelloggii).

4.1.2.2. AVOIDANCE AND MINIMIZATION EFFORTS
Valley Oak Woodland cannot be avoided during construction of a Project pipeline. In other portions of the Project, Valley Oak Woodland is near the development footprint and could be impacted as well.

Minimization efforts will include marking the limits of construction with temporary fencing.

Incorporation of this mitigation measure will ensure that construction impacts are limited to the Project area to avoid potential impacts to Valley Oak Woodland beyond those permitted by construction entitlements.

4.1.2.3. PROJECT IMPACTS
Impacts to the Valley Oak Woodland include construction of a proposed water pipeline along the northeastern portion of the BRAA. A total of 0.18 acre of Valley Oak Woodland will be temporarily disturbed due to Project construction (Figure 4). When the project grading design is finalized, prior to construction, a qualified botanist will count the number of qualifying trees over ≥5.5 inches diameter at breast height (DBH) that will be removed by the Project. The final tree removal determination will be made by City of Willits.

4.1.2.4. COMPENSATORY MITIGATION
The project proposes to mitigate the loss of Valley Oak Woodland with planting native trees at a 3:1 replacement ratio. The planting area is shown in Figure 5 but could be established in other portions of the property with approval from CDFW, such as within portions of the meadow habitat. Species to be planted will correspond with the impacted native trees. These may include valley oak and black oak trees. The native trees shall be obtained from a local nursery or propagated utilizing on-site acorns.

This assessment is based on preliminary impacts. When the project grading design is finalized, prior to construction commencing, a final count of trees to be mitigated will be made. Sanhedrin Timber Company will be responsible for successfully establishing replacement trees with an 80% survival performance standard and the City of Willits will be responsible for ensuring replacement plantings were successfully established.

Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 28 September 2022

4.1.2.5. CUMULATIVE EFFECTS
With implementation of replacement planting of oak trees, the Project will not result in adverse cumulative impacts to Valley Oak Woodland.

4.1.3. Discussion of Valley Oak Riparian Woodland

4.1.3.1. SURVEY RESULTS
Valley Oak Riparian Woodland, within the BRAA, is primarily located along drainages. Valley Oak Riparian Woodland is considered a natural community of special concern by CDFW. Valley Oak Riparian Woodland is dominated by valley oak (Quercus lobata), black oak (Quercus kelloggii), willow (Salix sp.), and Oregon ash (Fraxinus latifolia).

4.1.3.2. AVOIDANCE AND MINIMIZATION EFFORTS
Valley Oak Riparian Woodland cannot be avoided during construction of new roads and pipelines.

Minimization efforts will include marking the limits of construction with temporary fencing.

Incorporation of this avoidance measure will ensure that construction is limited to the Project area to avoid the potential for impacts to Valley Oak Riparian Woodland beyond those permitted by construction entitlements.

4.1.3.3. PROJECT IMPACTS
Impacts to the Valley Oak Riparian Woodland include construction of two new truck road watercourse crossings at Ditch 2 and installation of two new water pipelines, crossing Ditch 2 and Ditch 6. A total of

0.02 acre of Valley Oak Riparian Woodland will be temporarily disturbed due to Project construction.

The Project will result in the permanent loss of 0.15 acre of Valley Oak Riparian Woodland (Figure 4).

When the project grading design is finalized, prior to construction, a qualified botanist will count the number of qualifying trees ≥5.5 inches DBH that will be removed by the Project. The final tree removal determination will be made by City of Willits.

4.1.3.4. COMPENSATORY MITIGATION
The project proposes to mitigate the loss of Valley Oak Riparian Woodland with planting native trees at a 3:1 replacement ratio. The planting area is shown in Figure 5 but could be established in other portions of the property with approval from CDFW, such as within portions of the meadow habitat.

Species to be planted will correspond with the impacted native trees. These may include valley oak, black oak, willow, and Oregon ash trees. The native trees shall be obtained from a local nursery. This assessment is based on preliminary impacts. When the project grading design is finalized, prior to construction commencing, a final count of trees to be mitigated will be made. Sanhedrin Timber Company will be responsible for successfully establishing replacement trees with an 80% survival Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 29 September 2022
performance standard and the City of Willits will be responsible for ensuring replacement plantings were successfully established.

4.1.3.5. CUMULATIVE EFFECTS
With implementation of the revegetation measures, the Project will not result in adverse cumulative impacts to valley oak riparian woodland.

4.1.4. Discussion of Seasonal Wetland

4.1.4.1. SURVEY RESULTS
Seasonal Wetland, mapped as wet meadow in Figure 3, is a sensitive natural community. There are six seasonal wetlands (W1-W6) in the BRAA that may be considered jurisdictional features regulated under Section 401 and Section 404 of the Clean Water Act. Wetlands and waters are described below within the Preliminary Delineation of Wetlands and Other Waters of the U.S. (Appendix C). Dominant herbaceous species include those found within the Meadow habitat as well as rush (Juncus spp.) and sedge (Carex spp.). Three special status species were identified within BRAA Seasonal Wetlands: Davy’s semaphore grass (Plueropogon californicus var. davyi) in W5 and W6; North Coast semaphore grass (Pleuropogon hooverianus) in W4 and W5, and Baker’s meadowfoam (Limnanthes bakeri) in W6.

4.1.4.2. AVOIDANCE AND MINIMIZATION EFFORTS
Section 401 and 404 authorizations shall be obtained for impacts to state and federal wetlands and waters. During construction, water quality will be protected by implementation of best management practices (BMPs) of the California Stormwater Quality Association (CSQA 2021) as specifically outlined in the Stormwater Pollution Prevention Plan (SWPPP). Seasonal Wetland will be impacted during construction of the log yard, pond, wetland enhancement site, and road reconstruction. Minimization efforts will include marking the limits of construction with temporary fencing. Incorporation of this mitigation measure will ensure that construction is limited to the Project area to avoid the potential for impacts to Seasonal Wetland beyond those permitted by construction entitlements.

4.1.4.3. PROJECT IMPACTS
Proposed construction of a rocked log yard, a water storage pond, and a segment of road realignment in the northwest portion of the BRAA will impact seasonal wetlands W1 to W5. Construction related impacts are estimated to temporarily impact 0.01 acre of Seasonal Wetlands and result in the permanent loss of approximately 0.02 acre of Seasonal Wetland (Figure 4). Special-status species are mapped in Figure 3 and discussed in below in Section 4.2.

4.1.4.4. COMPENSATORY MITIGATION
The Project proposes to mitigate loss of wetland through wetland creation, mitigation bank credits, or in-lieu fees. An area in the northern portion of the BRAA has been identified as a potential location for Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 30 September 2022
on-site mitigation entailing creating a new seasonal wetland (Figure 5) . Should wetland creation mitigation be chosen to address impacts during 401 and 404 permitting, the proposed new wetland will be approximately 0.24 acre to satisfy a minimum replacement ratio of 3:1 for the Project’s permanent impacts to both Seasonal Wetland and Ditch habitats (Section 4.1.5). Wetland creation would require a Wetland Mitigation and Monitoring Plan (WMMP) be developed to mitigate the loss of functions and values of impacted Seasonal Wetland. A WMMP should include performance standards and success criteria, implementation details and schedule, monitoring methods and schedule, and contingency measures. In addition to wetland mitigations, areas of temporary disturbance within the Project footprint are proposed to be revegetated with native vegetation.

4.1.4.5. CUMULATIVE EFFECTS
Through wetland creation, mitigation bank credits, or in-lieu fees, the Project will not result in adverse cumulative impacts to Seasonal Wetland.

4.1.5. Discussion of Ditches 2 - 7

4.1.5.1. SURVEY RESULTS
Multiple drainages are located within the BRAA that flow into Ditch 1, the unnamed tributary to Mill Creek just east and north of the BRAA (Figure 3). These ephemeral and intermittent Ditches within the project are described below and within the Preliminary Delineation of Wetlands and Other Waters of the U.S. (Appendix C). Plant communities, primarily within the intermittent Ditches, consists of Mexican rush (Juncus mexicanus), common rush (Juncus effusus), and willow (Salix sp.). The hydrology within the BRAA appears to have been altered in multiple locations as evidenced by the shape and flow direction of the Ditches, as well as berms and possible dredging activities. Ditches 1 – 7 may be jurisdictional waters of the U.S. (Appendix C).

Ditch 1 is an intermittent water mapped as a Relatively Permanent Water (USFWS 2022). Ditch 2 is an intermittent drainage containing wetlands. Ditch 3 is an ephemeral and sparsely vegetated drainage that runs through the center of the southern portion of the Project; it is believed to be the original channel for Ditch 2. Ditch 4 is ephemeral with some wetland vegetation and appears to have been dredged along the parcel line at the center of the Project. Ditch 5 is intermittent water surrounded by wetlands containing rare plants. Ditch 6 is an intermittent stream that shows less signs of alteration than other drainages in the BRAA. Ditch 7 is an intermittent drainage ditch located at the north edge of the existing log yard.

4.1.5.2. AVOIDANCE AND MINIMIZATION EFFORTS
Section 401 and 404 authorizations shall be obtained for impacts to state and federal wetlands and waters. During construction, water quality will be protected by implementation of best management practices (BMPs) of the California Stormwater Quality Association (CSQA 2021) as specifically outlined Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 31 September 2022
in the Stormwater Pollution Prevention Plan (SWPPP). The BMPs will be designed to minimize the potential for siltation and downstream sedimentation in Ditch 1 and Ditch 6. Ditches 2 through 7 cannot be avoided. With the exception of Ditch 4, only minor impacts will occur. Ditch 4 is proposed to be filled to allow for site utilization.

4.1.5.3. PROJECT IMPACTS
Impacts to Ditches include filling Ditch 4, construction of new truck road drainage crossings of Ditch 2, minor road reconstruction impacts, and temporary impacts due to pipeline construction. A total of

0.01 acre of Ditch will be temporarily disturbed due to Project construction and an estimated 0.06 acre will be permanently impacted (Figure 4).

4.1.5.4. COMPENSATORY MITIGATION
As discussed in Section 4.1.4.4, the Project proposes to mitigate loss of Ditch and Seasonal Wetland through wetland creation, mitigation bank credits, or in-lieu fee mitigation. An area in the northern portion of the BRAA has been identified as a potential location for on-site mitigation entailing creating a new seasonal wetland (Figure 5).

4.1.5.5. CUMULATIVE EFFECTS
With implementation of the wetland mitigation and revegetation measures, the Project will not result in adverse cumulative impacts to Ditches within the BRAA.

4.2. Special Status Plant Species

4.2.1. Discussion of Baker’s meadowfoam (Limnanthes bakeri) Baker’s meadowfoam is an annual herb found in meadow, marsh/swamp (freshwater), valley/foothill grassland (vernally mesic), and vernal pool habitats from 574 to 2,986 feet. It blooms from April through May. There are 11 CNDDB recorded occurrences in the nine-quadrangle area surrounding the BRAA; all of which are within the Willits quadrangle. A large occurrence, covering 3-square miles and containing thousands of plants, is located just north of the BRAA. The southernmost polygon of this occurrence overlaps with the BRAA (CNDDB 2022).

4.2.1.1. SURVEY RESULTS
Baker’s meadowfoam was located within the BRAA during 2021 and 2022 surveys, north of the Project.

The Baker’s meadowfoam occurrence included 60 plants covering approximately 8-square feet of area near the outlet of a culvert on a non-appurtenant rocked road that travels west to east within the site boundaries (see Figure 3). The project is not proposing use of the road, and no maintenance or alterations are proposed near the Baker’s meadowfoam occurrence.

Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 32 September 2022

4.2.1.2. AVOIDANCE AND MINIMIZATION EFFORTS
No avoidance or minimization measures are proposed.

4.2.1.3. PROJECT IMPACTS
The Project will not impact Baker’s meadowfoam.

4.2.1.4. COMPENSATORY MITIGATION
No compensatory mitigation is proposed.

4.2.1.5. CUMULATIVE EFFECTS
No adverse cumulative effects were identified.

4.2.2. Discussion of North Coast Semaphore Grass (Pleuropogon hooverianus) North Coast semaphore grass is a perennial rhizomatous herb found in broadleafed upland forest, meadow/seep, and north coast coniferous forest (open areas, mesic) habitats from 35 feet to 2,200 feet (CNPS 2022). It blooms from April through June and has been observed in Mendocino, Marin, and Sonoma Counties. There are 7 CNDDB recorded occurrences in the nine-quadrangle area surrounding the BRAA, all of which are in the Willits quadrangle. An occurrence, 300 feet east of the BRAA, notes thousands of plants present from 2007 to 2012 and anticipated partial impact by construction of the Highway 101 bypass in Willits (CNDDB 2022).

4.2.2.1. SURVEY RESULTS
North Coast semaphore grass was found within the BRAA during the botanical surveys conducted in 2021 and 2022. A large population straddles Ditch 5.

4.2.2.2. AVOIDANCE AND MINIMIZATION EFFORTS
Minimization efforts will include marking the limits of construction with temporary fencing to prevent impacts to the North Coast semaphore grass population.

4.2.2.3. PROJECT IMPACTS
The Project will not impact North Coast semaphore grass.

4.2.2.4. COMPENSATORY MITIGATION
No compensatory mitigation is proposed.

4.2.2.5. CUMULATIVE EFFECTS
No adverse cumulative effects were identified.

Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 33 September 2022

4.2.3. Discussion of Davy’s Semaphore Grass (Pleuropogon californicus var. davyi)
Davy’s semaphore grass is a perennial rhizomatous herb found in cismontane woodland, lower montane coniferous forest, and meadows and seeps from 490 to 2000 feet (CNPS 2022). It blooms from March through June and has been observed in Mendocino, Lake, and Sonoma Counties (CalFlora 2022). There are 0 CNDDB recorded occurrences in the nine-quadrangle area surrounding the BRAA (CNDDB).

4.2.3.1. SURVEY RESULTS
Davy’s semaphore grass was found within the BRAA during the botanical surveys conducted in 2021 and 2022. A large population is located west of Ditch 5 within Wetland 4.

4.2.3.2. AVOIDANCE AND MINIMIZATION EFFORTS
Minimization efforts will include marking the limits of construction with temporary fencing to prevent impacts to the Davy’s semaphore grass population.

4.2.3.3. PROJECT IMPACTS
The Project will not impact Davy’s semaphore grass.

4.2.3.4. COMPENSATORY MITIGATION
No compensatory mitigation is proposed.

4.2.3.5. CUMULATIVE EFFECTS
No adverse cumulative effects were identified.

4.3. Special Status Animal Species Occurrences
During project scoping, 23 special status wildlife species were identified and reviewed to determine if suitable habitat is present within or directly adjacent to the BRAA (see Table 1). Of these 23 species, 3 were found to potentially have suitable habitat within the BRAA, and 1 was observed during spring 2022 at the margin of the BRAA. As discussed under Sections 4.3.3 and 4.3.4, bird surveys for community disruptions to special status birds are necessary.

Aquatic habitats within the BRAA where not found to be suitable for Northern California steelhead (Oncorhynchus mykiss), Chinook salmon (O. tshawytscha), and coho salmon (O. kisutch), known to spawn downstream in Mill Creek (0.3 miles from the BRAA). Mill Creek flows into Outlet Creek (1.1 miles from the Project site). The Highway 101 by-pass culvert may be an impassable barrier (located about 350-feet downstream of the BRAA) for fish. In addition, the ditches within and adjacent to the BRAA appears to be poor quality habitat, due to the low gradient flows creating brackish water and soil substrate.

Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 34 September 2022

4.3.1. Discussion White-Tailed Kite (Elanus leucurus)
White-tailed kites are non-migratory and are classified as Fully Protected under the California Endangered Species Act. In the western United States, white-tailed kites range from Baja California north to southwestern Washington (NatureServe 2022). In California, the yearlong range is from the southern border along the coast and through the Central Valley, to the northern border just along the coast (CDFW 2004). There are no CNDDB records of white-tailed kite occurrences in the 9-quadrangle area surrounding the BRAA. Of the 184 CNDDB occurrences, in Mendocino County, there is 1 occurrence on the coast from August 2006, between Albion and Elk near Big Salmon Creek. A pair of white-tailed kites were observed on the northeastern edge of the BRAA in May 2022. The observation was of 3 individuals near a nest tree in a small stand of 80- to 100-year-old redwood and Douglas fir trees.

White-tailed kites are known to inhabit open grasslands, meadows, marshes, foothills, and valley margins adjacent to deciduous woodlands in California lowlands west of the Sierra Nevada range. They prey on mostly voles and other small mammals and make their nests of loosely piled sticks near the top of dense oak, willow, or other trees near open foraging areas. The meadow and woodland plant communities of the BRAA provide both hunting and nesting habitat. Nesting occurs January through August, and avoidance and minimization measures are needed to prevent unnecessary disturbance.

4.3.1.1. SURVEY RESULTS
A pair of white-tailed kites was observed at the northeastern edge of the BRAA during a biological survey on May 7, 2022. Both nesting and hunting habitat is present within and adjoining the BRAA.

4.3.1.2. AVOIDANCE AND MINIMIZATION EFFORTS
If vegetation disturbance or removal is planned between January 15-August 15, nesting surveys should be conducted by a qualified biologist within 7 days prior to vegetation disturbance or removal. If an active white-tailed kite nest is found within or adjacent to Project boundaries, a 500-foot buffer or exclusion zone shall be established, in consultation with CDFW, until the nest becomes inactive as determined by a qualified biologist. Within the nesting season, should a white-tailed kite or raptor nest become active the applicant shall immediately establish a 500-foot buffer, work exclusion zone around the nest and contact CDFW.

4.3.1.3. PROJECT IMPACTS
Project construction has the potential to impact white-tailed kite nesting habitat in the Valley Oak Woodland and Valley Oak Riparian Woodland. This construction includes the development of two new truck road watercourse crossings at Ditch 2 and installation of two new water pipelines, one crossing Ditch 2 at the southern end of the BRAA and one crossing Ditch 6 along the northeastern portion of the BRAA. Tree removal associated with these developments is addressed in Sections 4.1.2 and 4.1.3.

Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 35 September 2022

4.3.1.4. COMPENSATORY MITIGATION
The project proposes to revegetate areas of temporary disturbance within the Project footprint with native vegetation. The applicant will replace removed native oak and riparian trees greater than 5 inches DBH at a ratio of 3:1. Preliminary planting areas are shown on Figure 4.

4.3.1.5. CUMULATIVE EFFECTS
No adverse cumulative effects were identified.

4.3.2. Discussion of Yellow Warbler (Dendroica petechia brewsteri) Yellow warbler is classified as a Species of Special Concern by CDFW and a Bird of Conservation Concern by USFWS. The yellow warbler occurs primarily as a migrant and summer resident in California form late March through early October and breeds from April to late July. This species breeds throughout most of California, excluding the Central Valley and Mojave Desert (Shuford et. al 2008).

Yellow warblers are known to frequent open to medium-density woodlands and forests with a heavy brush understory during their breeding period. Deciduous riparian areas with cottonwood, alder, willow, and other miscellaneous small trees and shrubs are ideal breading habitat. There are 78 CNDDB occurrences of yellow warbler throughout California, including one occurrence in Mendocino County (Willits Quad) from 1977. An unknown number of breeding birds was detected in Little Lake Valley north of Willits, where the habitat/ecosystem was described as “savanna dominated by Quercus lobata” and “ephemeral lake in valley during rainy season.” The yellow warbler was not observed in the BRAA, however, the Valley Oak Riparian Woodland could potentially serve as habitat for this species during breeding season. Avoidance and minimization measures are designed to avoid unnecessary disturbance in these areas.

4.3.2.1. SURVEY RESULTS
Yellow warbler was not present in the BRAA during BRA field visits. The seasonal drainages within the project area and surrounding Valley Oak and Valley Oak Riparian Vegetation could provide breeding season habitat for this species, although it should be emphasized that this habitat is relatively unsubstantial and low quality compared with surrounding areas.

4.3.2.2. AVOIDANCE AND MINIMIZATION EFFORTS
If vegetation disturbance or removal is planned between March 15-August 15, nesting surveys should be conducted by a qualified biologist within 7 days prior to vegetation disturbance or removal. If an active yellow warbler nest is found within project area boundaries, a 100-foot buffer or exclusion zone shall be established in consultation with CDFW until the nest becomes inactive as determined by a qualified biologist.

Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 36 September 2022

4.3.2.3. PROJECT IMPACTS
Project construction has the potential to impact yellow warbler nesting habitat in the Valley Oak Woodland and Valley Oak Riparian Woodland. This construction includes the development of two new truck road watercourse crossings at Ditch 2 and installation of two new water pipelines, one crossing Ditch 2 at the southern end of the BRAA and one crossing Ditch 6 along the northeastern portion of the BRAA. Tree removal associated with these developments is addressed in Sections 4.1.2 and 4.1.3.

4.3.2.4. COMPENSATORY MITIGATION
The project proposes to revegetate areas of temporary disturbance within the Project footprint with native vegetation. The applicant will replace removed native oak and riparian trees greater than 5 inches DBH at a ratio of 3:1. Preliminary planting areas are shown on Figure 4.

4.3.2.5. CUMULATIVE EFFECTS
No adverse cumulative effects were identified.

4.3.3. American Badger (Taxidea taxus)
American badger is classified as a Species of Special Concern by CDFW. The American badger is widely distributed in California. They are most abundant in drier open stages of most shrub, forest, and herbaceous habitats, with friable soils. Grasslands, savannas, and mountain meadows near timberline are preferred. This species requires sufficient food, friable soils, and open, uncultivated ground. They prey on burrowing rodents and dig burrows for themselves as well. Mating occurs in late summer or early autumn, followed by delayed implantation. There are 594 CNDDB occurrences of American badger throughout California, including two occurrences in Mendocino County (Sherwood Peak and Brushy Mtn./Jamison Ridge Quads) from 1916 and 1945. The closest recorded observation to the BRAA occurred in 1916 at Eden Valley Ranch, about 18 miles northeast of Willits. An American badger was not observed in the BRAA, however, there may be suitable Meadow habitat which would entail avoidance and minimization measures. However, if American badger is detected at this site in the future, all work should stop until proper mitigations are implemented as determined by CDFW.

4.3.3.1. SURVEY RESULTS
The American badger was not observed in the BRAA during biological surveys. Based on past occurrences, it is a low likelihood that this species would use the BRAA as habitat.

4.3.3.2. AVOIDANCE AND MINIMIZATION EFFORTS
In the unlikely event that an American badger den (evidenced by a large mound of dirt piled outside an excavated den) is encountered during construction of the Project, construction work shall halt, a qualified biologist shall evaluate the potential den site, and CDFW shall be notified if the hole is determined to be a potential American badger den.

Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 37 September 2022
A 100-foot no-work buffer shall be established around occupied maternity dens throughout the puprearing season, February 15 through July 1 and a 15-foot no-work buffer around occupied dens during other times of the year. If non-maternity dens are found and cannot be avoided during construction activities, they will be monitored for badger activity. If the biologist determines that dens may be occupied, passive den exclusion measures will be implemented for three to five days to discourage the use of these dens prior to project disturbance activities.

4.3.3.3. PROJECT IMPACTS
The Project has the potential to impact American badger, but mitigation measures will avoid or minimize impacts.

4.3.3.4. COMPENSATORY MITIGATION
No compensatory mitigation is proposed.

4.3.3.5. CUMULATIVE EFFECTS
No adverse cumulative effects were identified.

Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 38 September 2022
Chapter 5. Conclusion and Determination

5.1. Federal Endangered Species Act (FESA) Consultation Summary Projects that have the potential to effect federal endangered species require formal and informal consultation with USFWS and/or NMFW under FESA. The project will have no effect on federally listed species that either do not have the potential to occur in the BRAA or were not identified during floristic surveys of the BRAA. This Project will have no effect on Southern Oregon/Northern California coast coho salmon as ditch/stream features in the BRAA given the quality of ditch/stream habitats.

5.2. California Endangered Species Act Consultation Summary The BRAA was found to contain two state listed species: state endangered species Baker’s meadowfoam (Limnanthes bakeri), and state-threatened species North Coast semaphore grass (Pleuropogon hooverianus). Although not observed, the BRAA is within the range of and contains suitable habitats for state-endangered Roderick’s fritillary (Fritillaria roderickii) and Burke’s goldfield (Lasthenia burkei), and state threatened Milo Baker’s lupine (Lupinus milo-bakeri).

5.3. Wetlands and Other Waters Coordination Summary
A jurisdictional delineation was prepared for the BRAA (Appendix C). Six waters (Ditches 2 to 7) and five wetlands (W1 to W5) were identified within the BRAA. Based on preliminary engineering a total of approximately 0.02 acres of wetland and water features will be temporarily and 0.08 acres will be permanently impacted. The Project will require permits from the ACOE, CDFW, and the RWQCB. All permit conditions will be implemented.

5.4. Invasive Species
Invasive plant species in the BRAA rated by Cal-IPC (2021) are noted in Appendix A. Two species rates as High rated as “High” by Cal-IPC (2006) in terms of its ecological impact, invasive potential, and ecological distribution, occurs in the BRAA: Himalayan blackberry (Rubus armeniacus) and cheatgrass (Bromus tectorum).

The invasive plant species found in the BRAA are common throughout Mendocino County. The scope of this Project precludes effective eradication of these invasive species from the BRAA. The spread of invasive species in the BRAA will be reduced by cleaning equipment before it comes to the BRAA and re-vegetating disturbed areas native or sterile nonnative species. By revegetating disturbed creek Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 39 September 2022
banks and roadsides with native species, the Project will reduce the spread of these species in the BRAA.

Chapter 6. References
Calflora: Information on California plants for education, research, and conservation. 2022.

Berkeley, California: The Calflora Database. Online at: https://www.calflora.org/.

California Department of Fish and Wildlife (CDFW). 2018. California Natural Diversity Database. Wildlife and Habitat Data Analysis Branch, Sacramento, CA.

California Department of Fish and Game (CDFG). 2018. Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities. The Resource Agency, Sacramento, CA.

California Department of Fish and Wildlife (CDFW). 2022. Natural Communities. Biogeographic Data Branch. Online at: https://wildlife.ca.gov/Data/VegCAMP/NaturalCommunities#natural%20communities%20lists.

California Department of Fish and Wildlife (CDFW). 2004. California Wildlife Habitat Relationships System: White-tailed Kite Elanus leucurus.
https://nrm.dfg.ca.gov/Filehandler.ashx?DocumentVersionID=158278 California Invasive Plant Council (Cal-IPC) Inventory. 2017. Berkeley, CA. Accessed at https://www.calipc.org/plants/inventory/ California Native Plant Society, Rare Plant Program. 2022. Inventory of Rare and Endangered Plants of California (online edition, v9-01 0.0). Online at: https://www.rareplants.cnps.org.

California Natural Diversity Database (CNDDB). 2022. California Department of Fish and Wildlife, Biogeographic Data Branch. RareFind Version 5.

California Stormwater Quality Association (CSQA). 2021. Best Management Practices (BMPs), SWPPP.

Online at: https://www.casqa.org/resources/bmp-handbooks.

CNPS. 2022. A Manual of California Vegetation, Online Edition. California Native Plant Society, Sacramento, CA. Online at: http://www.cnps.org/cnps/vegetation/.

CalPhotos Database. 2022. University of California, Berkeley.

Online at: https://calphotos.berkeley.edu/flora/.

Biological Resource Assessment Report Sanhedrin Timber Company Clifton Environmental LLC 40 September 2022
Environmental Laboratory. 1987. Corps of Engineers Wetlands Delineation Manual. Department of the Army, Waterways Experiment Station, Vicksburg, Mississippi 39180-0631.

Federal Register. July 13, 1994. Changes in Hydric Soils of the United States. Washington, DC. (Definition of hydric soils.)
Holland, R.F. 1986. Preliminary Descriptions of the Terrestrial Natural Communities of California.

Sacramento, CA: California Department of Fish and Game.

Jepson Flora Project (eds.). 2022. Jepson eFlora. Online at: https://ucjeps.berkeley.edu/eflora/.

LeBallister’s Seed & Fertilizer. 2022. 1250 Sebastopol Road, Santa Rosa, CA 95407.

Online at: https://leballisters.com/.

Natural Resources Conservation Service. 2018. United States Department of Agriculture. Web Soil Survey. Accessed November 2018.

NatureServe. July 2022. NatureServe Explorer: Elanus leucurus White-tailed Kite. https://explorer.natureserve.org/Taxon/ELEMENT_GLOBAL.2.105756/Elanus_leucurus Sawyer, J.O., T. Keeler-Wolf, and J.M. Evens. 2009. A Manual of California Vegetation, Second Edition.

California Native Plant Society, Sacramento, CA. 1300 pp.

SHN Consulting Engineers. 2017. Quail Meadow Subdivsision Preliminary Biological Investigation Survey Report by Senior Biologist Warren Mitchell.

Shuford, W.D., and Gardali, T., editors. 2008. California Bird Species of Special Concern: A ranked assessment of species, subspecies, and distinct populations of birds of immediate conservation concern in California. Studies of Western Birds 1. Western Field Ornithologists, Camarillo, California and California Department of Fish and Game, Sacramento.

USDA, Natural Resources Conservation Service. 2010. Field Indicators of Hydric Soils in the United States, Version 7.0. L.M. Vasilas, G.W. Hurt, and C.V. Noble (eds.). USDA, NRCS, in cooperation with the National Technical Committee for Hydric Soils.

U.S. Fish & Wildlife Service (USFW). 2022. Information for Planning and Consulting (IPaC).

Online at: https://ecos.fws.gov/ipac/.

U.S. Army Corps of Engineers (ACOE). 2008. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region (Version 2.0).

Appendix A Plant and Wildlife Species Observed
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Appendix A Plant and Wildlife Species Observed
Plant Species Observed
Family Name Scientific Name Common Name Native? Cal-IPC Alismataceae Alisma lanceolatum lanceleaf water plantain No Alliaceae Allium bolanderi Bolander's onion Yes
Alingiaceae Liquidambar spp. liquidambar No
Amaryllidaceae Narcissus pseudonarcissus daffodil No
Anacardiaceae Toxicodendron diversilobum poison oak Yes Apiaceae Daucus carota wild carrot No
Conium maculatum poison hemlock No M
Foeniculum vulgare sweet fennel No
Torilis arvensis hedgeparsley No M
Apocynaceae Vinca major periwinkle No M
Asteraceae Achillea millefolium yarrow Yes
Artemesia douglasiana mugwort Yes
Baccharis glutinosa marsh baccharis Yes
Baccharis pilularis coyote brush Yes
Carduus pycnocephalus Italian thistle No M
Centaurea melitensis Maltese star thistle No M
Chamaemelum fuscatum chamomile No
Cichorium intybus chicory No
Cirsium vulgare bull thistle No M
Dittrichia graveolens stinkwort No M
Hypochaeris glabra smooth cat's ear No L
Hypochaeris radicata hairy cats ear No M
Lactuca spp. lettuce No
Matricaria discoidea pineapple weed Yes
Taraxacum officinale common dandelion No
Boraginaceae Myosotis discolor forget-me-not No
Brassicaeae Brassica rapa mustard No L
Caprifoliaceae Symphoricarpos spp. snowberry Yes
Caryophyllaceae Cerastium fontanum mouse ear chickweed No Spergula arvensis spurry No
Convolvulaceae Convolvulus arvensis field bindweed No
Cornaceae Cornus sericea ssp. sericea red osier dogwood Yes Cupressaceae Juniperus virginiana Eastern redcedar No
Cyperaceae Carex densa dense sedge Yes
Carex gracilior slender sedge Yes
Cyperus eragrostis nutsedge Yes
Appendix A Plant and Wildlife Species Observed
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Family Name Scientific Name Common Name Native? Cal-IPC Dipsacaceae Dipsacus fullonum wild teasel No M
Ericaceae Arbutus menziesii madrone Yes
Arctostaphylos standfordiana
spp. standordiana
Stanford manzanita Yes
Fabaceae Acmispon americanus American bird’s foot
trefoil
Yes
Gleditsia triacanthos honey locust No
Lathyrus latifolius sweet pea No W
Lathyrus sativus white pea No
Lotus corniculatus bird's foot trefoil No
Lupinus bicolor lupine Yes
Medicago polymorpha burclover No L
Trifolium dubium shamrock clover No
Trifolium repens white clover No
Trifolium subterraneum subterranean clover No
Vicia hirsuta hairy vetch No
Vicia sativa ssp. sativa garden vetch No
Fagaceae Quercus garryana Oregon oak Yes
Quercus kelloggii California black oak Yes
Quercus lobata valley oak Yes
Geraniaceae Erodium botrys big heron bill No
Erodium cicutarium redstem stork's bill No L
Geranium dissectum geranium No L
Geranium molle crane's bill geranium No
Hamamelidaceae Liquidambar styraciflua sweetgum No
Hypericaceae Hypericum perforatum common St. Johnswort No L Iridaceae Iris germanica german iris No
Sisyrinchium bellum blue eyed grass Yes
Juncaceae Juncus bolanderi Bolander's rush Yes
Juncus bufonius toad rush Yes
Juncus effusus Pacific rush Yes
Juncus ensifolius sword leaved rush Yes
Juncus mexicanus Mexican rush Yes
Lamiaceae Lamium purpureum purple dead nettle No
Melissa officinalis lemon balm No
Mentha pulegium pennyroyal No M
Lysimachia arvensis scarlet pimpernel No
Magnoliaceae Liriodendron spp. tulip tree No
Moraceae Morus spp. mulberry No
Myrsinaceae
Appendix A Plant and Wildlife Species Observed
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Family Name Scientific Name Common Name Native? Cal-IPC Oleaceae Fraxinus latifolia Oregon ash Yes
Onagraceae Epilobium ciliatum slender willow herb Yes
Epilobium densiflorum denseflower willowherb Yes
Orobanchaceae Triphysaria versicolor owl’s clover Yes
Papaveraceae Eschscholzia californica California poppy Yes Pinaceae Pinus ponderosa yellow pine Yes
Plantaginaceae Kickxia elatine cancerwort No
Plantago lanceolata ribwort No L
Plantago major common plantain No
Platanus racemosa western sycamore No
Veronica americana speedwell Yes
Poaceae Agrostis stolonifera redtop No L
Aira caryophyllea silvery hairgrass No
Alopecurus pratensis meadow foxtail No W
Anthoxanthum odoratum sweet vernal grass No L
Avena barbata slender oat No M
Briza maxima rattlesnake grass No L
Briza minor little rattlesnake grass No
Bromus diandrus ripgut brome No M
Bromus catharticus var. elatus chilean brome No
Bromus hordeaceus soft brome No L
Bromus sitchensis var.
carinatus
California brome Yes
Bromus tectorum cheatgrass No H
Cynosurus echinatus dogtail grass No M
Dactylis glomerata orchard grass No L
Danthonia californica California oatgrass Yes
Distichlis spicata saltgrass Yes
Elymus glaucus ssp. glaucus blue wild rye Yes
Elymus triticoides beardless wild rye Yes
Festuca arundinacea reed fescue No M
Festuca microstachys small fescue Yes
Festuca perennis Italian rye No M
Gastridium phleoides nit grass No
Holcus lanatus common velvetgrass No M
Hordeum murinum foxtail barley No M
Phalaris aquatica bulbous canarygrass No M
Phalaris lemmonii lemmon's canarygrass Yes
Phalaris paradoxa hood canarygrass No
Phleum pratense timothy No
Appendix A Plant and Wildlife Species Observed
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Family Name Scientific Name Common Name Native? Cal-IPC Plueropogon californicus var.
davyi
Davy’s semaphore grass Yes
Pleuropogon hooverianus North Coast semaphore
grass
Yes
Poa annua annual blue grass No
Poa compressa Canada blue grass No
Poa pratensis Kentucky blue grass No L
Polygonaceae Rumex acetosella sheep sorrel No M
Rumex crispus curly dock No L
Polemoniaceae Navarretia squarrosa skunkweed Yes
Ranunculaceae Ranunculus occidentalis buttercup Yes
Rosaceae Crataegus monogyna hawthorn No L
Luzula comosa wood rush Yes
Potentilla gracilis Northwest cinquefoil Yes
Prunus cerasifera cherry plum No L
Rosa gymnocarpa wood rose Yes
Rubus armeniacus Himalayan blackberry No H
Rubus ursinus California blackberry Yes
Rubiaceae Galium muricatum bedstraw Yes
Salicaceae Populus alba white poplar No
Populus nigra lombardy poplar No
Populus trichocarpa black cottonwood Yes
Salix laevigata red willow Yes
Salix lasiandra Pacific willow Yes
Salix lasiolepis arroyo willow Yes
Sapindaceae Acer rubrum red maple No
Acer saccharinum silver maple No
Aesculus californica buckeye Yes
Scrophulariaceae Scrophularia californica figwort Yes
Verbenaceae Verbena lasiostachys verbena Yes
Cal-IPC Inventory categorizes plants that threaten California’s natural areas. Ratings include High (H) – species that have sever ecological impacts, Moderate (M) – species that have a substantial and apparent- but generally not severe-co impact, Limited (L) – species that are invasive but their ecological impacts are minor, and Watch (W) – these species have been assessed as posing a high risk of becoming invasive.

Wildlife Species Observed
Common Name Scientific Name

AMPHIBIANS
Pacific treefrog Pseudacris sierra

INSECTS
bumble bee Bombus sp.

BIRDS
red-tailed hawk Buteo jamaicensis
Appendix A Plant and Wildlife Species Observed
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Common Name Scientific Name
white-tailed kite Elanus leucurus
quail Callipepla californica
turkey vulture Cathartes aura
red-winged black bird Agelaius phoeniceus
mourning dove Zenaida macroura

MAMMALS
deer Odocoileus hemionus
bobcat Lynx rufus

REPTILES
garter snake Thamnophis elegans elegans
fence lizard Sceloporus occidentalis occidentalis
Appendix B Photographs
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Appendix B Photographs
Appendix B Photographs
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Ditch 1 Ditch 1 Connection
Appendix B Photographs
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Ditch 2 Ditch 2
Appendix B Photographs
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Ditch 3 Ditch 3
Appendix B Photographs
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Looking east at Ditch 5 where it runs west-to-east. Looking west at Ditch 5 where it connects to Ditch 6.

Appendix B Photographs
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Looking north at Ditch 5 where it runs south-to-north. Looking south at Ditch 5 where it runs south-to-north.

Appendix B Photographs
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Looking south along Ditch 6. Looking north along Ditch 6.

Appendix B Photographs
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Looking south at Ditch 7 and toward the existing log yard. Looking north toward Ditch 7.

Appendix B Photographs
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Facing southwest, Wetland 4. Facing east, Wetland 4.

Appendix B Photographs
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Davy’s semaphore grass (Pleuropogon californica var. dayvi) in Wetland 4. Looking north at Wetland 5, Data Point 8.

Appendix B Photographs
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Baker’s meadowfoam (Limnanthes bakeri) in Wetland 6. Valley Oak Woodland location in BRAA Appendix B Photographs
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Valley Oak Riparian Woodland at the southern border of the BRAA, looking south. Valley Oak Riparian Woodland location in BRAA Appendix B Photographs
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Landscape Landscaped Woodland
Appendix B Photographs
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Disturbed/Fill Scrub
Appendix C Jurisdictional Delineation Report
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Appendix C Jurisdictional Delineation Report
PO Box 932., Redwood Valley CA 95470
(707) 234-1978
PRELIMINARY DELINEATION OF WETLANDS AND OTHER WATERS OF THE U.S.

SANHEDRIN TIMBER COMPANY LOG YARD PROJECT
23701 & 421 N. MAIN STREET

WILLITS, CALIFORNIA
JULY 2022
Project Description
The study area is located within the North Coast Range, in the valley floor of Little Lake Valley, with the northern most portion of the City of Willits, Mendocino County, California. The study area hosts upland habitats and several drainage ditches, wetland meadow, and riparian forest habitat. The proposed Project is an outdoor log storage yard.

Methodology
A routine-level wetland delineation of the study area was conducted on 3 April 2021 and 30 April, 5 May, 7 May, 10 May, and 13 May 2022. The purpose of the survey was to delineate all potentially jurisdictional wetlands1 and waters2 of the U.S. within the Study area. The delineation followed the U.S. Army Corps of Engineers (Corps) Wetland Delineation Manual (Corps 1987) and the Corps’ Western Mountains, Valleys, and Coast Region (WMVCR), Regional Supplement (Corps 2010). Other resources that aided in the delineation include The U.S. Army Corps of Engineers Jurisdictional Determination Form Instructional Guidebook (Corps 2007), the Ordinary High Water Mark Identification Regulatory Guidance Letter (Corps 2005) and Classification of Wetlands and Deepwater Habitats of the United States (FGDC 2013). Prior to field investigations, aerial photographs(NAIP 2016 & 2020), the Soil Survey of Mendocino County, Eastern Part (USDA 1991), the Willits USGS topographic map (USGS 1991) of the Study area, and preliminary project design maps were reviewed.

The National Wetland Plant List was reference to determine the wetland indicator status ratings of plant species found within the Study area. Wetland indicator status ratings definitions are in Appendix A.
1 See Wetlands in Appendix A.
2 See Waters of the U.S. in Appendix A.

Preliminary Delineation of
Wetlands and Other Waters of the U.S.

Sanhedrin Timber Co. Log Yard, City of Willits, CA
Clifton Environmental LLC 2 July 2022
13 complete wetland delineation data points were collected in the field (Appendix C), in addition 35 additional partial points were investigated to better understand the extent of hydrology and hydrophytic vegetation. Plant species identified within the Study area followed the Jepson Manual (Jepson 2022) nomenclature and were assigned a wetland indicator status3 based on The National Wetland Plant List (Corps 2018) for the WMVCR. Soils were analyzed at each complete data point for evidence of redoximorphic features. Moist soil colors were determined using the Munsell Color Chart (Greg MacBeth 2000).

Surveys were timed approximately two weeks after a suitable rain event when prolonged inundation and primary indicators of wetland hydrology could best be observed.

The Ordinary High-Water Mark (OHWM) of several drainage ditches were delineated (Corps 2005). The Study area ditches’ OHWM were delineated using physical characteristics and where absent were considered at bank full or were investigated for wetland parameters.

Data points were mapped in the field using the Avenza Maps app (trademark of Avenza Systems Inc.) on a mobile device. The width of Waters of the U.S. was measured in the field using a steel tape and ocular estimation. Data points and waters were subsequently overlain on a color digital orthophotograph using ESRI ArcGIS software. A summary of potential jurisdictional features can be found below in Table 2.

This report is a preliminary determination of wetlands and other waters of the U.S. on the study area. This determination is not considered complete until the Corps makes an independent assessment and issues a formal determination.

Study Area Description
The study area is located at 23701 & 421 N. Main Street in the City of Willits, Mendocino County, California, approximately 600 feet north of the Willits Highschool (Appendix B, Exhibit 1 & 2), covering approximately 22 acres. The Study area includes two assessor’s parcels (APN 108-040- 11 & 18). Land uses surrounding the Study area include industrial, commercial, and residential.

The Study area is characterized by five drainage ditch streams, herbaceous grassland, native and landscaped woodland, and scattered developments. The Study area is located on the Willits USGS

7.5’ quadrangle (USGS 1991) in portions of Section 7, T18N, R13W, MDBM [-123.742, 39.5284, NAD83] and Section 12, T18N, R14W. It lies within the Davis Creek Planning Watershed (1111.61.01) which is part of the Eel River Hydrologic Unit (Calwater 2004). Waters on the Study area flow into an unnamed tributary to Mill Creek, a tributary to Outlet Creek which flows into the Main Fork Eel, thence the Pacific Ocean. The elevation is approximately 1350 feet to 1365 feet above sea level.
3 See Wetland Indicator Abbreviations in Appendix A
Preliminary Delineation of
Wetlands and Other Waters of the U.S.

Sanhedrin Timber Co. Log Yard, City of Willits, CA
Clifton Environmental LLC 3 July 2022
Based on the Web Soil Survey (USDA 2021a), one soil type has been mapped within the Study area (Appendix B, Exhibit 3). The soil type is Cole silty clay loam, 0 to 2 percent (115), typically found in bottomlands in alluvium derived from sedimentary rock. It is somewhat poorly drained.

Cole silty clay loam is included in the hydric soils list, as about 10 percent of this soil unit includes minor components with hydric soil ratings (USDA 2021b).

Precipitation for the winter of 2021/2022 was far below average, as indicated in Table 1, although April precipitation was above average.

Table 1. Summary of Precipitation, Willits, California (NCEI 2022) and historic Willits, California (WRCC 2021)
Precipitation
October NovemberDecemberJanuaryFebruaryMarchAprilMa
y
JuneJuly
Totals
Winter
‘21/’22
(inches)
Oct 2021-
July 2022

11.14 4.08 11.98 1.77 0.00 1.36 7.11 0.28 -- -- 37.72
Historic
Average
(inches)
3/6/1902-
9/27/2012

3.08 7.35 9.81 9.74 7.96 7.60 3.14 1.49 0.39 0.07 51.40 Results
Preliminary wetlands and waters of the U.S. within the Study area are summarized in Table 2 and depicted in Appendix B, Exhibits 4. The Study area has a history of disturbance resulting in alterations to the hydrology, as evidenced by the flow patterns of the study area drainage ditches.

The Study area contains a combination of facultative, xeric/upland, and hydrophytic/wetland vegetation such as: valley oak (Quercus lobata, FACU), coyote brush (Baccharis pilularis, UPL), velvet grass (Holcus lanatus, FAC), willow (Salix sp., FACW), and rushes (Juncus sp, FACW). This mix of species may partially be a result of the site being in the interface between the Willits valley Mill Creek (wetland habitat), and surrounding hills (upland habitat). It could also be influenced by anthropogenic disturbances that have altered hydrological conditions over time. A complete list of identified plant species can be found in the 2022 Biological Resource Assessment Report covering the study area.

Preliminary Delineation of
Wetlands and Other Waters of the U.S.

Sanhedrin Timber Co. Log Yard, City of Willits, CA
Clifton Environmental LLC 4 July 2022
Ditch 1 is located approximately 70 feet east of the Study area. Ditch 1 is mapped as a Federal Water of the US in the USFWS online wetland mapper tool (USFWS 2021). It appears to be an intermittent, Relatively Permanent Water and is the unnamed tributary to Mill Creek that receives drainage from the study area.

Ditches 2, 3 &4 may were found to be Non-relatively Permanent Water and Ditch 5 &6 to be RPWs (Corps 2007).

Ditch 2 is intermittent with discontinuous seasonal flow and is characterized by a channel with a bed and bank, partially vegetated by herbaceous wetland plants and surrounded by a riparian forest community. There is a berm along most of the channels northern bank. The overstory of Ditch 2 is dominated by willow (Salix spp., FACW) shrubs and trees, valley oak (Quercus lobata), and white poplar (Populus alba). Herbaceous species include rush (Juncus spp., FACW) and pennyroyal (Mentha pulegium, OBL)
Dich 3 is an ephemeral ditch that has a bed and bank and is sparsely vegetated within the channel.

Dominate overstory species are largely landscaped trees - poplar (Populus X), sycamore (Platanus spp.), with few channel herbs.

Ditch 4 is ephemeral and flows west to east along the parcel line between the two study area parcels. It has a berm along its northern bank and is largely vegetated with herbaceous wetland species rush (Juncus spp., FACW) and pennyroyal (Mentha pulegium, OBL). See Data Point 1 (DP1) Ditch 5 is intermittent and originates at a culvert that drains the neighbor’s storage unit facility.

Although numerous drop inlets are evident throughout the neighbor’s site, it is not known the source of water discharging out of the culvert located in the northeast corner of the neighbor’s parcel and contributing to Ditch 5. The channel contained standing water (DP7) and herbaceous wetland plants (Juncus spp., FACW) and Davy’s semaphore grass (Pleuropogaon californicus var. davyi, OBL). The lower extent of Ditch 5 does not contain hydrophytic vegetation and is ephemeral as it flows into Ditch 6.

Ditch 6 is intermittent and travels through the mixed oak riparian woodland with a bed and bank and few herbs. The overstory is dominated by valley oak (Quercus lobata, FACU), black oak (Quercus kelloggii, NI), and Oregon ash (Fraxinus latifolia, FACW). Dogwood dominates the midlayer canopy (Cornus sericea, FACW), and poison oak (Toxicodendron diversilobum, FAC) and California blackberry (Rubus ursinus, FACU) the understory.

The study area’s herbaceous field habitat (mapped as meadow) is dominated by species such as reed fescue (Festuca arundinacea, FAC), velvet grass (Holcus lanatus, FAC), Himalayan blackberry (Rubus armeniacus, FAC), meadow foxtail (Alopecurus pratensis, FACW), and harding grass Preliminary Delineation of
Wetlands and Other Waters of the U.S.

Sanhedrin Timber Co. Log Yard, City of Willits, CA
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(Phalaris aquaticus, FACU). Portions of the meadow that were dominated by Facultative species were investigated for hydrology and soil indicators. Wetlands W1, W2, W3, W5, and W6 represent wet portions of the herbaceous field, while W4 was uncharacteristic. Wetland 4 may be formed as a result of past dredging and unidentified hydrology inputs seeping into the site from the adjacent storage unit parcel, or old Highway 101 development to the west. Extensive fill is deposited in this portion of the Study area and W4 was found surrounded by uneven terrain, is partially composed of a small potentially dredged pond, and the portion near Ditch 5 contains an abundant herbaceous, wetland community found inundated during the survey.

Table 2. Preliminary Wetlands and Waters of the U.S. in the Study Area Feature Acres/Linear Feet
Ditch 2 0.14
Ditch 3 to 6 0.24
W 1 (Wetland 1) 0.03
W2 0.07
W3 0.02
W4 0.13
W5 0.11
W6 0.61
Total 1.35
Plant Community Descriptions
Developed\Fill & Blackberry Scrub: Portions of the site are uneven, benching, bermed, and appear to be heavily disturbed, graded comprised of imported fill. These communities are characterized by poison hemlock (Conium maculatum), coyote brush (Baccharis pilularis), blackberry (Rubus ursinus), teasel (Dipsacus fullonum), harding grass (Phalaris aquatica), reed grass (Festuca aurundinacea), vinca (Vinca major) and/or poison oak (Toxicodendron diversilobum)
Landscaped Woodland: A mix of cultivars (Populus nigra), maple (Acer sp.), and sycamore (Plantanus racemose) are co-dominant in the tree canopy. Shrubs (e.g., Rubus sp.) and grasses (e.g., Festuca sp., Poa sp., Elymus sp., etc.) are co-dominant in the understory layers. This wellestablished, landscaped woodland occurs within the study area’ssouthern parcel where a former R.V.’s parking and recreational field were located.

Bluegrass/Fescue/Redtop Meadows: Poa pratensis, Festuca arundinacea, Phalaris aquatica, Alopecurus pratensis, and/or Phleum pratense are dominant or co-dominant in the herbaceous layer with Achillea millefolium, Bromus sp., Elymus sp., Hordeum sp., Juncus sp., or Taraxacum Preliminary Delineation of
Wetlands and Other Waters of the U.S.

Sanhedrin Timber Co. Log Yard, City of Willits, CA
Clifton Environmental LLC 6 July 2022
officinale. Emergent oak trees and hawthorn, plum and coyote brush shrubs are present at low cover. Wet portions of the meadow contain sedge (Carex spp.), rush (Juncus spp.), and Douglas’ baccharis (Baccharis glutinosa).

Oak Woodland: Located near the riparian woodland, the oak woodland areas did not exhibit wetland hydrology or soil indicators. Dominate overstory species include Quercus garryana, Quercus kelloggii, and/or Quercus lobata with blackberry and bluegrass (Elymus glaucus ssp. glaucus) in the understory.

Riparian Woodland: On the southern parcel the riparian woodland is younger, has fewer oaks and contains more invasive species. There a portion of the tree and shrub canopy is dominated by white poplar (Populus alba), Oregon ash, sycamore and willow. Oaks are found throughout the woodland. Other shrub species include dogwood, rose (Rosa californica), blackberry and hawthorn (Crataegus monogyna).

Regulations
Jurisdictional wetlands and other waters of the U.S. are regulated by the Corps under provisions of Section 404 of the Clean Water Act (33 United States Code [USC] § 403). Any disposal of dredged or fill material and structures, as well as work in wetlands or waters, requires a permit from the Corps. The Corps determines jurisdictional wetlands and / or other waters of the U.S. based on preliminary wetland delineations completed by wetland professionals and on-site evaluations and independent review by the Corps.

Under Section 401 of the federal Clean Water Act, the Corps is required to meet state water quality regulations prior to granting a Section 404 permit for work in a creek, river, or drainage.

This is accomplished by application to the local Regional Water Quality Control Board for Section 401 Certification that requirements have been met. In addition, the California Department of Fish and Game may regulate activities affecting or potentially affecting such resources.

References
Baldwin, B., ed. 2012. Jepson Manual: Higher Plants of California. University of California Press, Berkeley, CA.

Baldwin, B., ed. 2021. Jepson eflora. Accessed at: https://ucjeps.berkeley.edu/eflora/.

California Interagency Watershed Map (Calwater 2.2.1), 2004. Geospatial file.

Preliminary Delineation of
Wetlands and Other Waters of the U.S.

Sanhedrin Timber Co. Log Yard, City of Willits, CA
Clifton Environmental LLC 7 July 2022
Federal Geographic Data Committee (FGDC). 2013. Classification of wetland and deepwater habitats of the United States. FGDC-STD-004-2013. Second Edition. Wetlands Subcommittee, Federal Geographic Data Committee and U.S. Fish and Wildlife Service, Washington, DC.

Greg MacBeth. 2000. Munsell Soil Color Charts.

Jepson Flora Project (eds.). 2021. Jepson eFlora. Online at: https://ucjeps.berkeley.edu/eflora/.

National Agricultural Inventory Project (NAIP). 2016 & 2018.

National Centers for Environmental Information (NCEI). 2022. Climate Data Online: Dataset Discover website accessed at https://www.ncdc.noaa.gov/cdo-web/datasets on May 4, 2022.

National Oceanic Atmospheric Administration (NOAA). 2017. California Nevada River Forecast Center website accessed at http://www.cnrfc.noaa.gov/monthly_precip.php on August 2, 2017.

Western Regional Climate Center (WRCC). 2012. Website accessed at https://wrcc.dri.edu/cgibin/cliMAIN.pl?ca9684 on June 10, 2021.

U.S. Army Corps of Engineers (Corps). 1987. Corps of Engineers Wetland Delineation Manual.

Environmental Laboratory. Vicksburg, Mississippi. January.

U.S. Army Corps of Engineers (Corps). 2005. Ordinary High Water Mark Identification. Regulatory Guidance Letter Number 05-05. December
U.S. Army Corps of Engineers (Corps). 2007. Jurisdictional Instructional Guidebook. May 30, 2007.

U.S. Army Corps of Engineers (Corps). 2010. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys, and Coast Region (Version 2.0).

Environmental Laboratory. Vicksburg, Mississippi. May.

U.S. Army Corps of Engineers (Corps). 2018. National Wetland Plant List, version 3.4; Species Detail Tool. US ACOE Engineer Research and Development Center Cold Regions Research and Engineering Laboratory, Hanover, NH. Website accesses at:
https://wetland-plants.sec.usace.army.mil/nwpl_static/v34/species/species.html?DET=001100 U.S. Department of Agriculture (USDA), Natural Resource Conservation Service. 1991. Soil Survey of Mendocino County, Eastern Part, and Trinity County, California.

Preliminary Delineation of
Wetlands and Other Waters of the U.S.

Sanhedrin Timber Co. Log Yard, City of Willits, CA
Clifton Environmental LLC 8 July 2022
U.S. Department of Agriculture (USDA), Natural Resources Conservation Service, Soil Survey Staff. 2021a. Web Soil Survey. Available online at the following link:
http://websoilsurvey.sc.egov.usda.gov/ on June 10, 2021.

U.S. Department of Agriculture (USDA), Natural Resource Conservation Service. 2021b. Hydric Soils of Mendocino County, Eastern Part and Southwestern Part of Trinity County, California. Accessed at the following link:
https://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/nrcseprd1316620.html U.S. Geological Survey (USGS), 1991, USGS 1:24000-scale Quadrangle for Willits, CA 1991: USGS Topo Quad 39123d3.

U.S. Fish and Wildlife Service (USFWS). May 2021. National Wetland Inventory website.

Available online at the following link: http://www.fws.gov/wetlands/ Federal Regulations
33 CFR 328.3.
33 USC §403 (Section 10 of the Rivers and Harbor Act of 1899) 33 USC §1344, (Section 404 of the Clean Water Act)
Preliminary Delineation of
Wetlands and Other Waters of the U.S.

Sanhedrin Timber Co. Log Yard, City of Willits, CA
Clifton Environmental LLC 9 July 2022

APPENDIX A

DEFINITIONS AND ABBREVIATIONS
Wetlands: “The U.S. Army Corps of Engineers (Federal Register 1982) and the Environmental Protection Agency (Federal Register 1980) jointly define wetlands as: Those areas that are inundated or saturated by surface or ground water at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs, and similar areas.” (Corps 1987)
Waters of the U.S.: Waters of the U.S. include, but are not limited to the following: any channel that has real or potential interstate commerce value including lakes, rivers, streams [including perennial and intermittent streams, and ephemeral streams that have an ordinary high water mark (OHWM)], tributaries to waters, mudflats, sandflats, wetlands, sloughs, prairie potholes, wet meadows, playa lakes, natural ponds, and impoundments of waters (33 CFR 328.3). The OHWM is described as the elevation delineating the highest water level that has been maintained for a sufficient period of time to leave evidence on the landscape.

Wetland Indicator Abbreviations
OBL = Obligate Wetland Plant (estimated probability of occurring in wetlands >99%) FACW = Facultative Wetland Plant (estimated probability >67% to 99%) FAC = Facultative Plant (estimated probability 33% to 67%) FACU = Facultative Upland Plant (estimated probability 1% to <33%) UPL = Obligate Upland Plant (estimated probability <1%) NI = No Indicator
Preliminary Delineation of
Wetlands and Other Waters of the U.S.

Sanhedrin Timber Co. Log Yard, City of Willits, CA
Clifton Environmental LLC 10 July 2022

APPENDIX B

MAP EXHIBITS
Exhibit 1 – Regional Location Map
Exhibit 2 – Project Orthophoto Map
Exhibit 3 – Soils Map
Exhibit 4 – Delineation Map
Sanhedrin Timber Company
Vicinity Map
Portions of Sec 7, T18N, R13W, &
Sec. 12, T18N, R14W
Willits USGS 7.5' Quadrangle t
0 1,000 2,000 4,000
Feet
CE LLC 5/16/22
Study Area
Service Layer Credits: Copyright:© 2013
National Geographic Society, i-cubed
1360 ft
1400 ft
1440 ft
1480 ft
Ditch 1
Ditch 2
Ditch 6
Ditch 3
Ditch 5
Ditch 4
Sanhedrin Timber Company
Orthophoto Map
Portions of Sec 7, T18N, R13W, &
Sec. 12, T18N, R14W
Willits USGS 7.5' Quadrangle t
0 100 200 400
Feet
CE LLC 5/16/22
Ditch
Study_Area
Main Street
1360 ft
1400 ft
1440 ft
1480 ft
Sanhedrin Timber Company
Soils Map
Portions of Sec 7, T18N, R13W, &
Sec. 12, T18N, R14W
Willits USGS 7.5' Quadrangle t
0 100 200 400
Feet
CE LLC 5/16/22
Study_Area
Main Street
Soil Unit
115
128
146
210
1360 ft
1400 ft
1440 ft
W6
W5
W4
W2
W1
W3
DP9
DP8
DP7
DP6
DP5
DP4
DP3
DP2
DP1
DP13
DP12
DP11
DP10
Ditch 1
Ditch 2
Ditch 6
Ditch 3
Ditch 5
Ditch 4
Sec 7
T18N R13W
Sec 12
T18N R14W
Sec 18
T18N R13W
Sec 13
T18N R14W
0 100 200
Feet
CE LLC 5/16/22
Ditch
Study_Area
Main Street
Data Point
Wetland Status
n
y
Partial Data Point
Vegetation Community
Blackberry Scrub
Developed
Disturbed/Fill
Landscaped
Landscaped Woodland
Meadow
Oak Woodland
Riparian Woodland
Water
Wet Meadow
Sanhedrin Timber Company
Deleneation Map
Portions of Sec 7, T18N, R13W, &
Sec. 12, T18N, R14W
Willits USGS 7.5' Quadrangle t
Preliminary Delineation of
Wetlands and Other Waters of the U.S.

Sanhedrin Timber Co. Log Yard, City of Willits, CA
Clifton Environmental LLC 16 June 2022

APPENDIX C

WETLAND DETERMINATION DATA FORMS
Data Point Forms 1-13
WETLAND DETERMINATION DATA FORM -\lllestern Mountains, Valleys, and Coast Region ProiecUSite: --' L'-. ,-l- J-',-*^ City/County: Mendocino ^ q [5-/-- Sampling Date: ' PfOJeCVSlIe: -- ' '- ) w 'Jvv\ vrry'vvurrrr'
Rpiticanuowne r, Cc\^v,c &vi^e- T.*bo. Co. state: L- sampling Point: I lnvestigato(s): Estelle P' Clifton Section, Township, nange: 9a- ? f flNJ R r3\''] Landform (hillslope, terrace, etc.l, Dith t Localrelief(concave,convex,none\:__@Slope(%):o subregion (LR$: 9efl 7,5u KtZu tat: 11.t{zttoN 'Long: -12i.?sz'7'wJ Datum: -!AD:[ Soit Map Unit Name: I / I fa l" 5i 11 u c (c.. u/ NW classification:

Are climatic / hydrologic conditions on the site typical for this time oiyear? Yes )( No -
(lf no, explain in Remarks.)
Are Vegetation
-,
Soil X , or ttydrology X significantly disturbed? Are "Normal Circumstances" present? Yes -
No {
Are Vegetation _, Soil or Hydrology
-
naturally problematic? (lf needed, explain any answers in Remarks.) SUMMARY OF FINDINGS - Attach site map showing sampling point locations, transects, important features, etc. '7ox lO
i;
;.1
iti
i.j,!
Hydrophytic Vegetation Present?
Hydric Soil Present?
Yes No
No
No
Yes X !s the Sampled Area
wlthin a Wetland? Yes X No
Wetland Hydrology Present? Yes j-
*"iil:- b^o'1't 't'{'t^ *"o-"zlc -"(o r I
forc-.*4- l,Ue
VEGETATION - Use scientific names of plants.

Tree stratum (Plot size: lbgO frc ,

1. 2.-

3. 4.
-
= Total Cover
Saolinq/Shrub Stratum (Plot size:

1. .
"d

3. ,'d
_

4. 5_
Total Cover
Herb Stratum (Plot size:

Lt 6 flcw

2. Fe5*r.(o. c.r,-,.*e(i'rr*.cc,=.C 2O ) FAe
Absolute Dominant lndicator
% Cover Soecies? Status
Percent of Oominant Species , ^ /1
That Are OBL, FACW, or FAC: t " s (A/B)
Dominance Test worksheet:

Number of Dominant Species
That Are OBL, FACW or FAC:

Total Number of Dominant
Species Across All Strata:
(A)
(B)
'r
Y
Prcvalence lndex worksheet:

Total o/o Cover of: Multiolv bv:

OBlsDecies x1=
FACW soecies x2 =
FAcsDecies x3=
FACUspecies x4= _
UPlsoecies x5=
Column Totals:
-
(A)
-
(B)
Prevalence lndex = B/A =
Woodv Mne Stratum (Plot size:
lo E =TotalCover
5o'lrt \z,S
1' "l'o' t' t At

2. ----= Total Cover
% Bare Ground in Herb Stratum

3. /.1.p,a-H^.c^ Qwl€Orvt*t 2O y ()ula. Ca.,tx ?q,uli6r Zo trr< s. C f) l"bi"-t.n .; li "+n^ 5 T+cil
A7. _

8.'

9.-

10. 't1.

Hydrophytic Vegetatlon lndicatorc:
_ 1 - Rapid Test for Hydrophytic Vegetation
-
2 - Dominance Test is >50o/o ,,
-
3 - Prevalence lndex is s3.0r :
-
4 - Morphological Adaptationsl (Provide supporting
data in Remarks or on a separate sheet)
-
5 - Wetland Non-Vascular Plantsr
-
Problemalic Hydrophytic Vegetationl (Explain)
llndicators of hydric soil and weUand hydroiogy nrust
be present, unless disturbed or problematic.
s,
Hydrophytic
Vegetatlon [, Present? Yes
-/XNo
-
+r
Remarks:

US Army Corps of Engineers Western Mountains, Valleys, and Coast - Version 2.0 SOIL

HYDROLOGY
Wetland
Primarv lndicators (minimum of one reouired: check all that aoolv) _ Surface Water (A1)
_ High Water Table (A2)
_ Saturation (A3)
_ Water Marks (81)
_ Sediment Deposits (B2)
_ Drift Deposits (83)
_ Algal Mat or Crust (B4)
_ lron Deposits (B5)
_ Surface Soil Cracks (86)
_ lnundation Visible on Aeriat tmagery (87)
_ SparselyVegetated Concave Surface (BB)
_ Water-Stained Leaves (B9) (except
liLRAl,2,1\and1;Bl
_ Salt Crust (811)
_ Aquatic lnvertebrates (813)
_ Hydrogen Sullide Odor (C't)
_ Oxidized Rhizospheres along Living Roots (C3)
_ Presence of Reduced lron (C4)
_ Recent lron Reduction in Titted Soils (C6)
_ Stunted or Stressed Ptants (D1) (LRR A)
_ Other (Explain in Remarks)
Sampling Point: __L
Secondarv lndicators (2 or more reouired)
_ Water-Stained Leaves (B9) (mLRA f , 2,
.,. 44, and 48)
--iDrainage
Patterns (B10)
_ Dry-Season Water Tabte (C2)
_ Saturation Visible on Aeriat tmagery (C9)
_ Geomorphic Position (D2)
_ Shallow Aquitard (D3)
_ FAC-Neuhat Test (D5)
_ Raised Ant Mounds (D6) (LRR A)
_ Frost-Heave Hummocks (D7)
Western Mountains, Valleys, and Coast - Version 2.0
v
*
ProfileDescription:(Describetoth9depthneededto
Depth I
Remdrks
lType: C=Concentration, D=Depletion, RM=Reduced Matrix, cS=covered or coated sand Grains. 2location: pl =pnre I inina ,M=rrrarril Hydric Soil tndicatorc:
_..Histosol (A'l)
_ Histic Epipedon (A2)
_ Black Histic (A3)
_ Hydrogen Sulfide (A4)
_ Depleted Below Dark Surface (A1 1)
_ Thick Dark Surface (A12)
_ Sandy Mucky Mineral (Sl)
_ Sandy Gleyed Matrix (S4)
-
Sandy Redox (S5)
Stripped Matrix (SO)
Loamy Mucky Mineral (Fl) (except ilLRA i)
Loamy Gleyed Matrix (F2)
Depleted Matrix (F3)
Redox Dark Surface (F6)
Depleted Dark Surface (F7)
Redox Depressions (F8)
-
2cmutuck (iro)
_ Red Parent Materiat CIF2)
_ Very Shallow Dark Surface (TF12)
_ Other (Explain in Remarks)
3lndicators of hydiophytic vegetation and
wetland hydrology must be present,
unless disturbed or problematic.
,
x
strictive Layer (if present):

Type:

Depth (inches): Hydric Soil Present? yes X i,lo
Remarks:

Surface Water Present? Yes _ No _ Depth (inches):

Water Table Present? yes Y No _ Depth (inches): 12 ' '
Recorded Data (stream gauge, monitoring we
uS Army Corps of Engineers
(Applicable to all LRRS, unless otherwlse noted.)
Wetland Hydrology Present? V"" X No
-
xemarKS:

P
"tirl'
. .1 '..
q5!
WETLANDDETERMINATIoNDATAFoRM-WesternMountains,Valleys,andCoastRegion tr--/- /
'/ b 'z'a*-
-
sampling oate,",/ 2'.'?1-
Applicanuowner'. 9 *^ €- state:L- sampqng Point: ?.
::::r":',:ff1 Itfveuugarq\or.
^, + t)
Landform (hitlstope, terrace, "t".l G /4 Local relief (concave' convex' """t)t +;ili I i > ; ', Slope (7o):^--l4tat lO SoilMapunitName: "S- C'le S'l'{y'aLc'l -' NWclassification:

Ara .rim,ri^ / hv.trot^nir cnnrtitions on the site tvpical for this#e of year? Yes Y No -
(lf no, explain in Remarks')
Are climatic / hydrologic conditions on the site typical for year? Yes Are vegetation _, soit or Hydrology
-
significanuy disturbed? Are "Normal circumstances" present? Yes -
No
-
AreVegetation-,soilorHydrology-naturallyproblematic? (lf needed, explain any ans\rvers in Remarks') i,
I
suMMARy oF FINDINGS - Attach site map showing sampling point locations, transects, important features, etc' ls the Sampled Area
wlthin a wetland? v."-L No
Hydrophytic V..egetation Present?
Hydric Soil Present?
Wetland Hydrology Present?
Yes -fNo
-
Yes X NoD.o,5l,i YL{r L.3 si';'^' , Trtc: V)L'-hl -,
VEGETATION - Use scientific names of plants'
Number of Dominant SPecies
That Are OBL, FACW or FAC:

Total Number of Dominant
Species Across All Strata:

Percent of Dominant SPecies
That Are OBL, FACW, or FAC:
250"-
Saolino/Shrub Stratum (Plot size: )
Woodv Vine Stratum (Plot size:
20 v {AL
20 '. FAc
-
I O 'i,l Ft <-
.( ^ Tlcu
2- __o_ '-\tr|--
z --b--
Nr I
ffi . S kr FAo
l{"iiM | -h-r'K'n
4l =Totalcover
ra'/, -- fl. S

10. % Bare Ground in Herb Stratum
I
+
v
OBL species
FACW species
FAC species
FACU species
UPL species
Column Totals:

XyOroptrytlc vegetation lndicators:
-
1 - Rapid Test for Hydrophytic Vegetation
-
2 - Dominance Test is >50%
-
3 - Prevalence lndex is 33.01
-
4 - Morphological Adaptationsl (Provide supporting
data in Remarks or on a separate sheet)
-
5 - Wetland Non-Vascular Plantsr
-
Problematic Hydrophytic Vegetationl (Explain)
tlndicators of hydric soil and wetland hydrology must
be present, unless disturbed or problematic.

Hydrophytic
Vegetation \, Pre-sent? Yes;! No
US Army Corps of Engineers Western Mountains, Valleys' and Coast - Version 2 0 7o'/,= ll ,f
-
x2=
-
x3=
-
x4=
-
x5=
-
(A)
Prevalence lndex = B/A =
Sampling Point:

HYDROLOGY
to document thElndicatoior confirm
q-7
E:ltr
Matrix _ Redov tre:r,-:.e, cotor(moist) yo @
t
r' l-t-/-
ll--(
^4^^/r
Hydrlc Soil lndicators:
_ Histosol (Al)
_ Histic Epipedon (A2)
_ Black Histic (A3)
_ Hydrogen Sutfide (A4)
_ Depleted Betow Dark Surface (A11)
_ Thick Dark Surface (A12)
_ Sandy Mucky Minerat (Sl)
_ Sandy Gleyed Matrix (S4)
(Applicable to alt LRRs, untess otheEtse noGIJ
_ Sandy Redox (SS)
_ Stripped Matrix (56)
_ Loamy Mucky Minerat (F1) (except ilLRA 1)
_ Loamy Gteyed Matrix (F2)
-X Depteted Matrix (F3)
_ Redox Dark Surface (F6)
_ Depleted Dark Surface (F7)
_ 2 cm Muck (AiO)
_ Red Parent Material (TF2)
_ Very Shallow Dark Surface (TF12)
_ Other (Explain in Remarks)
3lndicators of hydrophyfic vegetation and
wetland hydrology must be present,
unless disturbed or problematic.

Hydric Soit Present? yes X No _
_ Surface Water (Al)
_ High Water Tabte (A2)
_ Saturation (A3)
_ Water Marks (B't)
_ Sediment Deposits (B2)
_ Drift Deposits (B3)
_ Algal Mat or Crust (B4)
_ lron Deposits (BS)
_ Surface Soil Cracks (86)
_ lnundation Visible on Aerial lmagery (87)
_ Water-Stained Leaves (89) (except
MLRA 1, 2,1A, and 4Bl
_ Salt Crust (811)
_ Aquatic lnvertebrates (813)
_ Hydrogen Sutfide Odor (Cl)
_ Oxidized Rhizospheres atong Living Roots (C3)
_ Presence ofReduced lron (C4)
_ Recent lron Reduction in Tiiled Soits (C6)
_ Stunted or Stressed plants (D1) (LRR A)
_ O(her (Explain in Remarks)
Secondarv lndicators (2 or more reouired)
_ Water-Stained Leaves (89) (MLRA i, 2,
4A, and 48)
_ Drainage patterns (B10)
_ Dry-Season Water Tabte (C2)
_ Saturation Visibte on Aeriat lmagery (C9)
_ Geomorphic position (D2)
_ Shallow Aquitard (D3)
_ FAC-Neutrat Test (D5)
_ Raised Ant Mounds (D6) (LRR A)
_ FroslHeave Hummocks (D7) _ SparselyVegetated Concave Surface (Bg) Surface Water present?
Water Table Present?
Saturation Present?
Yes- No X Depth(inches):

Yes Y No_ Depth(inches):

Yes X No_ Depth(inches): I ;i Wetland Hydrology present? y"s X No Describe Reco
l^Jate. l^tlr ,: ,.ol ir-^*di,.lr<\ b"(r.^, tle ,rr1r.,.kd h,r.e- ?.

US Army Corps of Engineers
Western Mountains, Valleys, and Coast _ Version 2.0
WETI.ANDDETERMINATIoNDATAFoRM-WesternMountains,Valleys,andCoastRegion r-( ) 1 ' ' -).-- T. *,Ll r' ( O citylcountv: Mendocino sampling 961s") - r' -delProiecusite: " 'VJ'd- . \. /,. ' I vrtv'vvurrr'
state: cA sampling tot1.
, =? ,
ApplicanUOwner: ;'-
lnvestigato(s): Estelle P' Clifton - --
Section' Township' Range: .} t ' '
Ia --p r *. I + , {! Local relief(concave, convex, none): flaa'a- Slope (Yo): D 9uvrsvrvr I
Soil Map Unit Name: C"le S; I h o !"' -
- ' NW classification:

Are climatic / hydrologic conditions on the site typical for thiJime of year? yes X No -
(lf no' explain in Remarks')
Are vegetation
-,
soit x , or Hyclrology
-
significantly disturbed? Are "Normal circumstances" present? Yes _- ruo x Are Vegetation
-,
Soil or Hydrology
-
naturally problematic? (lf nee(led, explain any ans\ivers in Remarks.) ^'s
v vYvrY$v"
suMMARy oF FTNDTNGS - Attach site map showing ""rpring
point rocations, transects, imPortant features' etc'
ls the Sampled Area
withln a Wstland? Yes
-
No
HydroPhYtic Vegetation Present?
Hyclric Soil Present?
Wetland HYdrologY Present?
NoNor.lo X
-hywr^, r,(z\1 \ *f6 ' \ra( J; tl ", ,f'.ar"I JL* Ji{.L VEGETATION - Use scientific names of plants'
oo-minancerestworksheet:

Number of Dominant Species
That Are OBL, FACW, or FAC:

Total Number of Dominant
Species Across All Strata:

Percent of Dominant SPecies
ThAt ATE OBL, FACW' OT FAC:

Saolino/Shrub Stratum (Plot size:
2 i( -h'h1 a':7./F.';i'-rt.-;
---
tl.
^ f1 -.1 - zz rAVWt^dtAr^(Qlt r-'v -:.el=- "r, Lo {Ae\A l5 J =TotalCovet-1.. ,-/IZO
Woodv Vine Stratum (Plot size: )
o/o Bare Ground in Herb Stratum _.-
OBL sPecies
FACW sPecies
FAC sPecies
FACU sPecies
UPL species
Column Totals:
-
1 - Rapid Test for Hydrophytic Vegetation
-
2 - Dominance Test is >50o/o
-
3 - Prevalence lndex is s3 01
4 - Moroholoqical Adaptationsl (Provide supporting
- J"t" in Reharks or on a separate sheet)
-
5 - Wetland Non-Vascular Plantsl
-
Problematic Hydrophytic Vegetationr (Explain)
llndicators of hydric soil and wetland hydrology must
Oe present, unless disturbed or problematic'
HydrophYtlc
Vegetatlon Present? Yes
US ArmY CorPS of Engineers
Western Mountains, Valleys, and Coast - Version 2'0
,
Total % Cover of: Multiolv bv:

SOIL
:

Sampling point: =-j,

HYDROLOGY
or confirm the aba;;;; needed to : (DescribeE
Depth Matrix ";_:^^_.::
v' serrrlrrnrneaDsenceotandicators.)-
(inches)
@ rexture_ Remarks
(Appticabteto"[ln@
_ Histic Epipedon (A2)
_ Black Histic (A3)
_ Hydrogen Sutfide (A4)
_ Depteted Betow Dark Surface (A11)
_ Thick Dark Surface (A12)
_ Sandy Mucky Minerat (Sl)
_ Sandy Redox (S5)
_ Stripped Matrix (56)
-
Loamy Mucky Minerat (F1) (except MLRA i)
_ Loamy Gteyed Matrix (F2)
_ Depleted Matrix (F3)
X Redox Daft Surface (F6)
_ Depteted Dark Surface (F7)
_ 2cm Muck (A10)
_ Red parent Material (TF2)
_ Very Shaflow Dark Surface (TF12)
_ Other (Explain in Remarks)
'lndicators of hydrophytic vegetation and
wetland hydrology must be present,
Hydric Soil present? yes Y No
-
Surface Water (A1)
_ Water_stained Leaves (89) (except
-
High water Tabte (A2) irLRA t, 2,44, and 48)
_ Saturation (A3)
_ Satt Crust (811)
-
Water Marks (B'l)
_ Aquatic lnvertebrates (813)
-
sediment Deposits (82) _ Hydrogen Sutfide odor (C1)
-
Drift Deposits (B3) _ Oxidized Rhizospheres atong Living Roots (C3) _ Atgat Mat or Crust (84) presence of Reduced lron (C4) _ lron Deposits (BS) Recent lron Reduction in Tiflect Soits (C6) _ Surface Soit Cracks (86) Stunted or Stressed ptants (D1) (LRR A) _ lnundation Visibte on Aeriat lmagery (87) Other (Exptain in Remarks) _ Sparsely Vegetated Concave Surface (88)
Secondarv lndicators (2 or more reouired)
_ Water-Stained Leaves (89) (MLRA f , 2,
4A, and 48)
_ Drainage patterns (BlO)
_ Dry-Season Water Tabte (C2)
_ Saturation Visible on Aerial lmagery (C9)
_ Geomorphic position (D2)
_ Shailow Aquirard (D3)
_ FAC-Neutrat Test (D5)
_ Raised Ant Mounds (D6) (LRR A)
_ Frost-Heave Hummocks (D7)
Yes
-
ruo fl Depth (inches):
surface water Present? yes _ N" + Depth (inches):
water Table Present? yes _ r.ro X Depth (inches):

Saturation Present? ycc rr^ n ^^_.- ..

Wetland Hydrology present? yes
_ No y
oata(stre@
US Army Corps of Engineers
Western Mountains, Valleys, and Coast _ Version 2.0
WETLAND DETERMINATTON DATA FORM -Western Mountains, Valleys, and Coast Region ProjecVSite: ."- -l-o)n; T;^ l,tn Cn CitY/CountY: Mendocino sampring D^8 5'5 ' )'> ApplicanUOwner, t u
State: CA Sampling Point -Ill *'? rn*' -n,sIFLandform (hillslope, terrace, etc.1: 't^\\ a+ $ nH Local relief (con*r", .onr"r, none): fl-rat-14-- Slope (%): b Subregion (LRR): tat: Zcl .4ZZi ' long: - f z9, 3 52 S o ,nur^, lltO €Z Soir Map Unir Name: Crle Si l\ cb I NW ctassification:

Are climatic / hydrologic conditions on the site typical for this time of year? V"r Y No -
(lf no, explain in Remarks.)
Are Vegetation
-,
Soil
-,
or Hydrology
-
significantly disturbed? Are "Normal Circumstances" present? Yes V ruo lnvestigato(s): Estelle P. Clifton Section, Township, Range:

Are Vegetation _, Soil or Hydrology _ naturally problematic? (lf needed, explain any answers in Remarks.) SUMMARY OF FINDINGS - Aftach site map showing sampling point locations, transects, important features, etc.

Hydrophytic Vegetation Present?
Hydric Soil Present?
Wetland Hydrology Present?
Yes X No
Yes _ No
Yes _ No
v Is the Sampled Area
within a Wetland? Yes- lo X
VEGETATION - Use scientific names of plants.

Tree Stratum (Plot size:

1. Absolute Oominant lndicator
% Cover Soecies? Status
(A)
(B)
(A/B)
Total Number of Dominant
Species Across All Strata:

Percent of Dominanl Species
That Are OBL, FACW, or FAC:

Domlnance Test worksheet:

Number of Dominant Species a
That fue OBL, FACW or FAC: O
2 3.
4 Saolinq/Shrub Stratum

1. (Plot size:
-
= Total Cover
Total o/o Cover of: Multiolv bv:

OBLspecies x1=-
FACWspecies x2= _
FACspecies x3= _
FACUspecies x4= _
UPLspecies x5=_
Column Totals: _ (A) _
(B)
Prevalence lndex = B/A =

2. 3.
4 5.
= Total Cover
Herb Stratum (Plot size: )
't.Q-ru^;L @ rO Y rn.
,.n*-^ ^;;,ffi7 -'Z|') {hL
,.:ffi ) tAcu Hydrophytic Vegetation lndlcators:
_ 1 - Rapid Test for Hydrophytic Vegetation
_ 2 - Dominance Test is >50o/o
-
3 - Prevalence lndex is s3.01 'r
-
4 - Morphological Adaptationsr (Provide supporting
data in Remarks or on a separate sheet)
-
5 - Wetlancl Non-Vascular Plantsi
-
Problematic Hydrophytic Vegetationr (Explain)
tlndicators of hydric soil and wetland hydrology must
be present, unless disturbed or problematic.
4 { r<i-'r) Qr ^.<Le-.cjq PAL
s. V)?.5^rn, .Drltar"a*- b fAc
6 2- Nl
, B"r^^W 2-*, FAc\i

8. 9,
't0.

11. 1U =Total Cover
WoodvVineStratum (Plotsize: g1alt -- 910/o
'1. 7oolc i ll,Lo/" Hydrophytlc
Vegetatlon
Pr&ent? ves I No- 2
% Bare Ground in Herb Stratum
= Total Cover
Remarks:

US Army Corps of Engineers Western Mountains, Valleys, and Coast - Version 2.0 SOIL sampring eoint Ll-
.,i:

Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicatots.) Depth
(inches)
Redox Features _
Texture Remarks
o- 1 ..,.slre/> jtl$-, .!*, J-o-*.
4- lv ?.5/K '/z ?O
?,sl,R_ {t to
fz - te 7{/K s/z- 7 0
7, f,rr ?/r t, s, (h "L-,- r,sir t la a0
EE 4 7a7ae, LS Et"l -z\ c h 'TZq;
Type: C=Concentration, D=Depletion, RM=Reduced Matrix, CS=Covered or Coated Sand Grains. 2Location: PL=Pore Lining, M=Matrix Hydric Soil Indlcators: (Applicable to all LRRs, unless othervise noted.) Indlcatorc for Problematic Hydric Soilse:
_ Histosol (A1) _ Sandy Redox (S5) _ 2 cm Muck (A10)
_ Histic Epipedon (A2) _ Stripped Matrix (56) _ Red Parent Material (TF2) -
Black Histic (A3)
-
Loamy Mucky Mineral (Fl) (except MLRA 1)
-
Very Shallow Dark Surface (TF12)
-
Hydrogen Sulfide (A4) _ Loamy Gleyed Matrix (F2) _ Other (Explain in Remarks) -
Depleted Below Dark Surface (A1 1) _ Depleted Matrix (F3) -
Thick Dark Surface (A12)
-
Redox Dark Surface (F6) 3lndicators of hydrophytic vegetation and -
Sandy Mucky Mineral (S1)
-
Depleted Dark Surface (F7) wetland hydrology must be present, &J" -
Sandy Gleyed Matrix (S4) _ Redox Depressions (F8) unless disturbed or problematic.

Type:

Depth (inches): Hydric Soil Present? Yes _ No x
Remarks:

Alr "s+ Fb

HYDROLOGY
weuano irydrology lndicatons:

Primarv lndicators (minimum of one reouired: check all that aDolv) Secondarv lndicators (2 or more reouired) _ Water-Stained Leaves (89) (except _ Water-Stained Leaves (B9) (MLRA f _ Surface Water , 2, (Al)
_ High Water Table (A2)
_ Saturation (A3)
_ Water Marks (Bl)
_ Sediment Deposits (82)
_ Drift Deposits (83)
_ Algal Mat or Crust (B4)
_ lron Deposits (85)
_ Surface Soil Cracks (86)
_
lnundation Visible on Aerial lmagery (B7) _ Other (Explain in Remarks) _ SparselyVegetated Concave Surface (88)
4A, and 48)
_ Drainage Patterns (810)
_ Dry-Season Water Tabte (C2)
_ Saturation Visible on Aerial lmagery (C9)
_ Frost-Heave Hummocks (D7)
MLRA 1,2,4A,and4,Bl
_ Salt Crust (811)
_ Aquatic lnvertebrates (813)
_ Hydrogen Sulfide Odor (C1)
_ Oxidized Rhizospheres along Living Roots (C3) _ Geomorphic Position (D2) _ Presence of Reduced lron (C4) _ Shallow Aquitard (D3) _ Recent lron Reduction in Tilled Soils (C6) _ FAc-Neutral Test (DS) _ Stunted or Stressed Plants (Dl) (LRR A) _ Raised Ant Mounds (D6) (LRR A) Field Observatlons:

Surface Water Present? Yes
-
ruo \ Depth (inches):
water Table present?
"", -
no T DeDth (inches):

Saturation present?
"". -
*o T Depth (inches): 7
(includes capillary fringe)
Wetland Hydrology Present? Yes
-
ffo X
DescribeRecordedData(streamgauge,monitoringwell,aerialphotos,pre@ Remarks:

US Army Corps of Engineers Western Mountains, Valleys, and Coast - Version 2.0 Hydrophytic Vegetation Present?
Hydric Soil Present?
Wetland Hydrology Present?
Yes
Yes Ii
Yes X
NoNo
ls the Sampled Area
within a Wetland? Yes Y No
Remarks:
'--- >
Areclimatic/hydrologicconditionsonthesitetypical forthistimeofyear? yes X No_ (lf no,explaininRemarks.) Are vegetation _, soil _, or Hydrology _ significanfly disturbed? Are ,,Normal circumstances" present? yes ( No Are Vegetation _, Soil or Hydrology _ naturally problematic? (lf needed, explain any ans\,\rers in Remarks.) SUMMARY oF FINDINGS - Aftach site map showing sampting point locataons, transects, important features, etc.

VEGETATION - Use scientific names of plants.

US Army @drps of Engineers
';

2. 3.

4. Tree Straturn,. (Ptot size: i2 1. "rr
Absolute Dominant lndicator
% Cover Soecies? Status
= Total Cover
-ffi*;- 5 fAc 5 LAL
5o Y FAC Ig VACw
7 EAa
} FAtv
"-1 p Y {-fic
Saplino/Shrub Stratum

1. =&*
.a
(Plot size:
,al

2. 3.

4. 5.

Herb Stratum (Plot size: )
Algpecuu us pra{euErs
" Y ?4\t co. a( wv'A'r na r e.:r
- f) i?S a cr^.s {dl o n ,^ ,ut
Jt^^ (+.5 vUovi Ccri.wvn'

1. 2.

3. 4.

5. 6.

7. 8.

9. 10.
1't.

2. Woodv Vine Stratum (Plot size:

1. o/o Bare Gfrund in Herb Stratum
lo\ =Total Cover
"C'lo 511.5"/o
7o "/ . ?l.l lo
DominanceTestwffi
Number of Dominant Species C
Tfiat Are OBL, FACW, or FAC: - (A)
Total Number of Dominant
Species Across Atl Strata: - @)
Percent of Dominant Species
That Are oBL, FACW, br FAC: I oO r:'le,y
Prevalence lndex worksheet:
-
Total % Cover of: Multiolv bv:

OBL species x 'l = _
FACWspecies x2= _
FACspecies x3=_
FACUspecies x4= _
UPlspecies x5= _
Column Totals: __ (A) _
(B)
Prevalence lndex = B/A =
Hydrophytac Vegetation !ndlcators:
-
1 - Rapid Test for Hydrophytic Vdiltation
_ 2 - Dominance Test is >S0%
_ 3 - Prevalence lndex is s3_01
_ 4 - Morphological Adaptationsr (provide supporting
data in Remarks or on a separate sheel)
_ 5 - Wetland Non-Vascular plantsl
_ Problematic Hydrophytic Vegetationr (E4plain)
llndicators of hydric soil and wefland hydrology must
be present, unless disturbed or problematic.

Hydrophytic Vegetation \./ Present? ves a. No_
Remarks
r(r
Western Mountains, Valleys, and Coast - Version 2.0
WETLAND DETERMINATION DATA FORM a -Western Mountains, Vatteys, and Coast Region projecusite: :>^rl-)g ,u fu*" (, city/county:-Mendocino ;;";:;".- q-l- Z L Appicanvowne, - \.
-,,
k::::ffiljl;f
lnvestigator(s): EstelleP.clifton _ . Secrion,Township,n"ng", -CA.? T.t(NJ tLtB\, Landform (hillslope, terrace, "t.i, 4 ^[ a( Locat relief (concave, convex, nonel: n Oh C Slope (%): O Subregion (LRR): _
soir MapunirName: .o," =,' rr, ( o ..-; "" %'o"nt
#oatum:
t'Jeat &3
t
Sampling Point:

Hydric Solt lndicatoF:
_ Histosol (A1)
(Applicable to all LRRS, unless otherwise noted.) lndicators for Problematic Hydrlc _ 2 un Muck (A10)
_ Red Parent Material (TF2)
_ Histic Epipedon (A2)
_ Black Histic (A3)
_ +lydrogen Sulfide (A4)
-
gepleted Below Dark Surface (A'll)
_ Thick Dark Surface (A12)
_ Sandy Mucky Mineral (S1)
_ Sandy Gleyed Matrix (S4)
__ Sandy Redox (S5)
-_ Stripped Matrix (56)
-
Loamy Mucky Mineral (F1) (except If,LRA r)
_ Loamy Gleyed Matrix (F2)
Deoleted Matrix (F3)
X Redo, Dark Surface (F6)
_ Depleted Dark Surface (F7)
_ Redox Depressions (F8)
_ Very Shallow Dark Surface (TF12)
_ Other (Explain in Remarks)
3lndicators of hydrophytic vegetation and
wetland hydrology must be present,
unless disturbed or problematic.

Hydric Soil Present? ves X No
Remarks:
nLFA rq -Cc^{.,.'[ Ch (or'slnl Vrtte.Ss 't b1 "u,drnce of, {1."A,n3 "r goalt^3 Primarv lndicators (minimum of one reouired: check all that aoolv) -
Surface Water (A1) ! Water-stained Leaves (Bg) (except
Remarks:
lndicators:
_ High Water Table (A2)
-
Saturation (A3)
_ Water Marks (Bl)
_ Sediment Deposits (B2)
-'Drift
Depcsits (83)
_ Algal Mat or Crust (84)
_
lron Deposits (85)
_ Surface Soil Cracks (86)
_
lnundation Visible on Ae'ial lmagery (87)
_ SparselyVegetated Concave Surface (B8)
MLRA l, 2,4A, and 48)
_ Salt Crust (B11)
_ Aquatic lnvertebrates (813)
_ Hydrogen Sulfide Odor (Cl)
-
Oxidized Rhizospheres along Living Roots (C3)
_ Presence of Reduced lron (C4)
-
Recent lron Reduction in Tilled Soils (CG)
-
Stunted or Stressed Plants (Dl) (LRR A)
_ Other (Explain in Remarks)
Secondarv lndicators (2 orrnore required)
_ Water-Stained Leaves (Bg) (MLRA 1, 2,
4A, and,fB)
_ Drainage Patterns (B10)
_ Dry-Season Water Table (C2)
_ Saturation Visible on Aerial lmagery (Cg)
_ Geomorphic Position (D2)
_ Shallow Aquitard (D3)
_ FAc-Neutral Test (D5)
_ Raised Ant Mounds (D6) (LRR A)
_ Frost-Heave Hummocks (D7)
Surface Water Present?
Water Table Present?
Saturation Present?
Describe Data (stream gauge, monitoring well,
Yes
-
f.fo )4 Depth (inches):

Yu, ,X No
-
Depth (inches): I 1 :'
ves X No- Depth(inches): -J-3"--
previous inspections),
US Army Qorps of Errgineers Western Mountains, Valleyg and Coast - Version 2.0 SOIL
E
-,
z-IT -tsr(->t r 40 , rYRs.s/t -+ c' t 7,-.YQ, s/p 1 c ^n 10t7.qrA s/t aO c A/\ -/ 0 q;r; tzSr k s/t. <0 clA
1r-aa./'=/' RM=Flertrreed Matrix. CS=Covered or Coated Sand Grains. 2Location: PL=Pore Lining, M=Matrix.

Type:

Depth (inches):

Wetland Hydrology Present? """ X No
-
t.

WETLAND DETERMINATION DATA FORM -Western Mountains, valleys, and coast Region projecvsite: €- l,ilr*'* T',r^Vl. Co city/county: Mendocino samplingort", 5--- 7 -i"l- ^r;;;;;*,
state: cA s"rqiis Point _6 , _
tnvestigator(s): Irt"lb Prc!ft- Sec{ion, Township, nrng", 5;, " ? T18 N R lt UJ Landform(hillSlope,."*".",.Local.relief(concave,convex'none)../,6^2-Slope(%):?- subregion(LRR): y61. 37,r?31o tong: -tzj-is?s u
Datum: t,*Ddj
Sol Map Unit Name: nl" Si t\ c-(Q'1 NW classification:

Are climatic / hydrologic conditions on the site typical for this time of year? Yes --X- No -
(lf no, explain in Remarks.)
Are vegetation _, soil or Hydrology
-
significanfly disturbed? Are "Normal circumstances'present? Yes -XNo
Are Vegetation
-,
Soil
-,
or Hydrology
-
naturally problematic? (lf needed, explain any answers in Remarks.) suMMARy OF FINDINGS - Attach site.map showing sampling point locations, transects, important features, etcHydrophytic Vegetation Present? Hydric Soil Present?
Wetland HydrologY Present?
Yes
Yes
Yes
No
No
No
Y
T
ls the Sampled Area
urithin a Wetland? Yes uoX
m epr;- t> ?: 4rea- / +,rr,'ltd. g ll t tascd o^* (o.
€r''e'i eg
?
VEGETATION - Use scientific names of plants.

Tree Stratum (Plot size:

Saolino/Shrub Stratum (Plot size:
a.f

3. 4.

5. 6.

7. 8.

WoodY Vine Stratum (Plot size:

Absolute Dominant lndicator
% Cover Soecies? Status
= Total Cover
-=
Total Cover
lE V UPL
5 - YAL
S YACJO FAc

1. 2.

3. 1.

4. ,.-?nsTp.J; '^ 35 fac r UPL
.ql
lp
I Zo = Total cover

1. 2.
. ,2.i.= l4
Sii, ' 60
-=
Total Cover
o/o Bare Ground in Herb Stratum
Herb Skatum (Plot size:
t. Lol\yvtttt>
Oominance Test worksheet:

Number of Dominant Species
That Are OBL, FACW Or FAC:

Total Number of Dominant
Species Across All Strata:

Perc€nt of Dominant Species
That Are OBL, FACW or FAC:
7-- (A)
(B)
4_7 <*rt
Prevalence Index worksheet:

Total % Cover of: Multiolv bv:

OBLspecies x1=-
FACwspecies x2=
-
FACspecies x3=-
FACUspecies x4=
-
UPlspecies x5=
-
Column Totals:
-
(A)
-
(B)
Prevalence lndex = B/A =
Hydrophytlc Vegetatlon lndicatoE:
_ 1 - Rapid Test for Hydrophytic Vegetation
_ 2 - Dominance Test is >50%
-
3 - Prevalence lndex is s3.01
-
4 - Morphological Adaptationsr lProvide supporting
data in Remarks or on a separate sheet)
-
5 - Wetland Non-Vascular Plantst
-
Problematic Hydrophytic Vegetationl (Explain)
'lndicators of hydric soil and r,vetland hydrology must be present, unless disturbed or problematic.

Hydrophytlc
Vegetation t
Present? v"":[- No
- Remarks:

US Army Corps of Engineers Western Mountains, Valleys, and Coast - Version 2.0 ,o j (4L
.Dt
'11.
!1(Q
Sampling Point:

Description: (Describ
DePth
-:

MeUx Redox Features (inches) @ Texture Remarks
(Applicable to all LRRs, unless otherwlse noteaJ
_ Histic Epipedon (A2)
_ Black Histic (A3)
_ Hydrogen Sulfide (A4)
_ Depleted Below Dark Surface (A11)
_ Thick Dark Surface (A12)
_ Sandy Mucky Minerat (S1)
_ Sandy Gleyed Matrix (S4)
_ Sandy Redox (S5)
_ Stripped Matrix (S6)
_ Loamy Mucky Minerat (Fl) (except MLRA r)
_ Loamy Gleyed Matrix (F2)
_ Depleted Matrix (F3)
_ Redox Dark Surface (F6)
_ Depldted Dark Surface (F7)
_ Redox Depressions (F8)
_ 2cm Muck (A10)
_ Red Parent Material (TF2)
_ Very Shaltow Dark Surface (TF12)
_ Other (Explain in Remarks)
3lndicators of hydrophytic vegetation and
wetland hydrology musl be present,
unless disturbed or problematic.

Yes- no X

HYDROLOGY
Primarv lndicators (minimum of one reouired: check all that aoolv) _ Surface Water (Al)
-
High Water Table (A2)
_ Saturation (A3)
_ Water Marks (Bl)
_ Sediment Deposits (82)
_ Drift Deposits (83)
_ Algal Mat or Crust (B4)
_ lron Deposits (85)
_ Surface Soil Cracks (86)
_ lnundation Visible on Aerial lmagery (87)
_ Sparsely Vegetated Concave Surface (Bg)
_ Water-Stained Leaves (89) (except
iiILRA 1, 2,1A, and 4Bl
_ Salt Crust (B11)
. Aquatic lnvertebrates (813)
_ Hydrogen Sulfide Odor (Cl)
_ Oxidized Rhizospheres atong Living Roots (C3)
_ Presence of Reduced lron (C4)
_ Recent lron Reduction in Tiiled Soils (C6)
_ Stunted or Stressed Ptants (Dl) (LRR A)
_ Other (Explain in Remarks)
Secondarv lndicators (2 or more reouired)
.
_ Water-Stained Leaves (89) (MLRA r, 2,
.tA, and 48)
_ Drainage Pattems (810)
_ Dry-Season Water Table (C2)
_ Saturation Visible on Aerial lmagery (Cg)
_ Geomorphic Position (D2)
_ Shallow Aquitard (D3)
_ FAc-Neutrat Test (D5)
_ Raised Ant Mounds (D6) (LRR A)
_ Frost-Heave Hummocks (D7)
Surface Water Presenf? yes
-
"o
X Depth (inches):

Water Table Present? yes _ No V Depth (inches):

Saturalion Present? yes _ f'lo ,( Depth (inches): Wetland Hydrology Present? yes Recorded Oata (stream
US Army Corps of Engineers Western Mountains, Valleys, and Coast - Version 2.0

SOIL -Y-/
E
,r 1 ,)
i#,
I
*=91';:TI'*+?-
l^') F.RM 1r--);;;t:;'?: - western Mountains, varreys, and coast Resion ProjecUsite:

ApplicanUOwner: ' (( tt City/County: Mendocino
sampring o^t", 5*1 -z'2'
lnvesiigator(s): Estelle P. Clifton State: CA
-
eadi^^ y------..
- a ----l.Tpling Point -1
suoiegion(LRR): =--l
'rlrr-Ir Local relief(concave,convex,no*1,
^-!-,-]"ililI- ;u*"r*:: "'[''*o '= .*:"::j::::H:I;-
ff H#
--,
il,l
--,
:: ;;.# * :flffiTHi*; Are "Norma, circumsrances. presenr? yes -
No k
slJMMApv ,.,E Erlr,.rrr^. -
rrq'urqrlv Plsoremauc'/ (lf needed, explain any ansvvers in Remarks.) ,",;;;;;;;", ;""":rilil;l',"atu I Hydrophytic Vegetatio res, etc

VEGETATTON
- Use scientific n"."" Jpi"nt".

Tree Stratum (plot size.

1. % Cover Soecies? si;i,
Absolute

2. 3.

4. (Plot size: \
= Total Cover

1. 2.

3. 4.

5. Herb Stratum (Plot size: \
t o1od-d:f-"^: . i ".c Det-
_ = Total Cover
't.

2. 3.

4. 5.

6. 7.
3o
s
lC,
Y
-)- fAcw
fAcw
orc

8. 9.

10. 't1.

Woodv Vine Stratum (plol size: I
-lto
b9 /*l
,= Total Cover
% Bare Ground Total Cover in Herb Stratum
Western Mountains, Valleys, and Coast _ Version 2.0
.i"
Hydrophytic Vegetation present?
Hydric Soil present?
Wetland Hydrology present?
Yes
Yes
Yes
No
No
No
ls the Sampled Area
within a Wefland?
Di{.t ,Su.Lu- *r icLl a.r
y..+a pr osa** A
-
t {(on ?ol<. n
r24* i*,
N_umber of Dominant Species
I hat Are OBL, FACW or FAC: .
@)
Total Number of Dominant
SPecies ecross Ar Stiata,' Z
<ay
Lercent of Dominant Species rnatAreOBL,FACWorFAC: t OD We) Total % Cover of: Multiplv bv; OBlspecies vr-
-^rFACWspecies -, -
-
FACspecies veFACUspecibs + x4=
UPLspecies vaColumn Totals: /a\
_ 1 - Rapid Test for Hydrophytic Vegetation
_ 2 - Dominance Test is >so%
_ 3 - prevalence lndex is s3.0r
_ o - Ygip.nopgicat Adaptarionsi lprovide supportinq data in Remarks or on a separale ,t _ 5 - Wetland Non-Vascular plantsl "Ay--'"",
Problematic Hydrophytic Vegetationr (Explain)
'lnclicators of hydric soil and wefland hydrology must be present, unless disturbed or problemati".'-, "'--'
Yes X No_
US Army Corps of Engineers
Saolino/Shrub Stratum
l,,i:
.
:, .I
.."fr
,uHi
,.1
,H
, #id-'I
I
qAi ,,,. 1.Ti',,,. / ', 0..,,-'&H
-...j{'rtrs
'r;+1v'
Depth ffi Texture -
6r.-D^i.,^a,l urtriv CS=Covefed Or COatt
Hydric Soil lndicatorc: @herwisenoted.)
Histosol (Al)
I Histic Epipedon (PC)
-
Black Histic (A3)
-
Hydrogen Sulfide (A4)
]- olpr"teo Below Dark Surface (A11)
: Thick Dark Surface (A12)
SanclY Mucky Mineral'(F1.)
-
SandyRedox (S5)
-
StriPped Matrix (56)
-
L93q!y Mucky Mineral (Fl) (excepi MLRA l)
-
LoamY Gleyed Matrix (F2)
X DePleted Matrix (F3)
-
Redox Dark Surface (F6)
-
DePletecl Dark Surface (F7) 'j
tnd#6,s 6r ProbtematltHydric soils'
-
ZcmMuck (A1O)
Red Parent Material (TF2)
Very Shallow Dark Surface (TF12)
-
Other (Explain in Remarks)
'lndicators of hydrop"hytic vegetation and
wetlgld hydrology must be present'
!,-*'
Hydric Soil Present? """ X *o
-
',.1
SecohdaN lndicators (2 ormore required)
-
Water-stained Leirlp (Bg) (MLRA 1, 2'
4A, and 48)
,.
'
-
Drainage Patterns (B1o)
Surface Water (A1) .

High Water Table (A2)
Saturation (A3)
Water Marks (B'l) t
Sediment Deposits (82)
Drifl DePosits (83)
Algal Mat or Crust (84)
lron Deposits (85)
Surface Soil Cracks (86)
lnundation Vi$ible on Aerial lmagery (B7)
Sparsely V6getated Concave S1t* t98l
uLRA 1, 2,4A' and 48)
Salt Crust (Bl'l)
Aquatic lnvertebrates (Bl 3)
Hydrogen Sulfide O<tor (C1)
OxiOizeO Rhizospheres along Living Roots (C3)
Presence of Reduced lron (C4)
Recent lron Reduction in Tilled Soils (C6)
Stuntecl or Stressed Plants (D1) (LRR A)
Other (ExPlain in Remarks)
-
Dqb6eason Water Table (C2) .,j$$
-
Saiuration Visible on A€ttatl'nager{
-
Shallow Aquitard (D3)
-
FAo-Neutrel Test (D5) 'l'
-
Raised Ant Mounds (D6) (LRR A)
Frost-Heave Hummocks (D7)
iWetlald Hytlrology Present? Yes
-
No
-
Yes No Depth (inches):
v ^ll v". l No- Depth(inches): t
Surface Water Present?
Water Table Present?
Saturation Present?
if available:

HYDROLOGY
.'i{'.1-
.s,:

Ji.! i
, , lll'
,j r*
US Army CorPs of Engineers
Western Mountains, Valleys, and Coast - Version 2 0
WETLAND DETERMINATION DATA FORM - Western Mountains, Valleys, and Coast Region C" 5 1-?L
City/County: Mendocino Sampling Date:

ApplicanuOwner: t' State: !l- SamPling Point:
lnvestigato(s): Estelle P' clifton section, Township, Range: f21 ? ?'l 8-N tL t 3 UJ Landform (hillslope, terrace, etc.): { c\d Localrelief(concave,conVex,none):-!LSlope(%):o Subregion (LRR):
- Mtons: -l?-3,3szso Datum:MAb 4s
Soil Map Unit Name: NW classification:

Are climatic / hydrotogic conditions on the site typical for this time of year? Yes -X.

No
-
(lf no, explain in Remarks')
Projecusite: Sc ^h oaL"\ TW lol-r
Are Vegetation
-,
Soil or Hydrology significantly disturbed?
Are Vegetation
-,
Soil or Hydrology
-
naturally problematic?
tl
Are "Normal Circumslances" present? Yes .-X- No
(lf needed, explain any answers in Remarks.)
suMMARy OF FINDINGS - Attach site map showing sampling point locations, transects, important features, etc. ls tho Sampled Area
wlthin a Wetland? ves z\ No
Hydrophytic Vegetation Present?
Hydric Soil Present?
Wetland Hydrology Present?
ves X. ruo
Yes V No
VEGETATION - Use scientific names of plants.

Number of Dominant Species I
That Are OBL, FACW or FAC: (A)
Total Number of Dominant I
Species Across All Strata: I (B)
Percent of Dominant SPecies
That Are oBL, FAcw, or FAc: -l os
1A/B)
Saolinq/Shrub Stratum (Plot size:

41. ^ l'
s. fP)t "biu-* :lli".l-^

6. M/ds,'s diJcolt r
Woodv Vine Stratum (Plot size:
o/o Bare Ground in Herb Stratum
Tolal o/o Cover of:

OBLspecies
-
x1=
FAcwspecies
-
x2=
FACsoecies x3=
FACUspecies
-
x4=
Column Totals:
-
(A)
Prevalence lndex = B/A =
_ 1 - Rapid Test for Hydrophytic Vegetation
_ 2 - Dominance Test is >50%
-
3 - Prevalence lndex is 33.01
-
4 - Morphological Adaptationsl (Provide supporting
data in Remarks or on a separate sheet)
-
5 - Wetland Non-Vascular Plantsl
-
Problematic Hydrophytic Vegetationl (Explain)
tlndicators of hydric soil and wetland hydrology must
be present, unless disturbed or problematic.

Hydrophytic
Vegetation v
Present? Yesl 1{o
US Army Corps of Engineers Western Mountains, Valleys, and Coast - Version 2.0 Yes
Tree Stratum (Plot size:

1. 2.

3. 4.
't.

2. J.

4. 5.

2. 3.

7. 8.

9. 11 /
Absolute Dominant
% Cover Soecies? Status
lndicator
= Total Cover
-
= Total cover

LO Y TAL
Ykcv
s ogL
lo Lt =Totat Cover
5"h".,

10. 't.
-=
Total Cover
Prevalence lndex worksheet:

Multiolv bv:
:s
sotL

HYDROLOGY
Sampling Point
] rt*, g=p*@=l"jr*o .r",nr, ".="*** ", "*,"0 ".* or.;, .,**ffi HydricSoillndicatorB:(App!lcabletoallrProblematicHytlricSoi!s':
-
Histosol (A1) _ Sandy Redox (SS) _ 2 cm Muck (A1O) ' Histic Epipedon (A2) -
stripped Matrix (s6)
-
Red parent Material (rF2)
-
Black Histic (A3)
-
Loamy Mucky Mineral (F1) (except MLRA l)
-
Very Shailow Dark Surface (TF12)
-
Hydrogen Sulfide (A4)
-
Loamy Gleyetl Matrix (F2) _ other (Exptain in Remarks)
_ Depleted Below Dark Surface (Al 1) _ Depteted Mafix (F3) -
Thick Dark Surface (A12) -[ neOox Dark Surface (F6) 3lndicators of hydrophytic vegetation and _ Sandy Mucky Mineral (Sl) _ Depleted Dark Surface (F7) wefland hydrotogy must be present, _ Sandy Gleyed Matrix (S4) _ Redox Depressions (F8) unless disturtced or probtematic. strictive Layer (if present):

Type: l
Depth (inches): Hydric Soil Present? v"" X NoRemarks:

Primarv lndicators (minimum of one reouired: check all that aoolv) _ Surface Water (Al)
_ High Water Table (A2)
_ Saturation (A3)
_ Water Marks (81)
_ Sediment Deposits (B2)
_ Drift Deposits (83)
_ Algal Mat or Crust (84)
_ lron Deposits (85)
_ Surface Soil Cracks (86)
_ Water-Stained Leaves (89) (except
I|LRA l, 2,4A, and 48)
_ Salt Crust (811)
_ Aquatic lnvertebrates (813)
_ Hydrogen Sulfide Odor (C.t)
_ Oxidized Rhizospheres along Living Roots (C3)
_ Presen@ of Reduced lron (C4)
_ Recenl lron Reduction in Tilled Soils (C6)
_ Stunted or Stressed plants (D1) (LRR A)
Secondarv lndicators (2 or more reouired)
_ Water-Stained Leaves (89) (irLRA i, 2,
4A, and 48)
_ Drainage Patterns (BlO)
_ Dry-Season Water Table (C2)
_ Saturation Visible on Aerial lmagery (C9)
-
Geomorphic Position (D2)
_ Shallow Aquitard (D3)
_ FAC-Neutrat Test (D5)
_ Raised Ant Mounds (D6) (LRR A)
_ Frost-Heave Hummocks (D7)
-
lnundation Visible on Aeriar rmagery (B7) _ other (Exprain in Remarks) _ Sparsely Vegetated Concave Surface (B8)
Surface Water Present? yes _ No X Depth (inches):

Water Table present? yes -K_ No _ Depth (inches): -]77- Saturation Present? Yes X, No_ Depth (inches): b. S f Wetland Hydrology present? V"" \. No _ , aerial photos, previous in+ectionglif aiaitaOiE
US Army Corps of Engineers Western Mountains, Valleys, and Coast _ Version 2.0 rrorre uescatpuon:
v
Depth
(inches)
o_(tf
,tc
4Er
Texture Remarks Color (moist) o/o

1.Cvr< =/-> t6,, frWr^ A

1.> f R1/i aa
-
WETLAND DETERMINATION DATA FORM -Western Mountains, Valleys, and Coast Region q,*-[,ir'; '(;*h (, Mendocino samprins su* C - -7 'YY
ProjecUSite: City/County:
lt State: [- Sampling Point:
section, Township, n"ng", 9. -? 716 'U E\\ \*J
Local relief (concave, convex, none):
-!}&&-
Slope (%): o
Lat gq,Ll?3+' tong: '1L3.!SLb" Datum l"'+D 83
\(
ApplicanUOwner:
lnvestigato(s): Estelle P' Clifton
Landform (hillslope, terrace, etc.):

Subregion (LRR)
soir Map unit Name: C"l r s)\h,, .(-., 1 - - NW classification:

Are climatic / hydrologic conditions on the site typical for this time of year? Yes Y No -
(lf no, explain in Remarks.)
Are Vegetation _, Soil or Hydrology significantly disturbed? Are "Normal Circumstances" present? Yes X No Are Vegetation _, Soil _, or Hydrology
-
naturally problematic? (lf needed, explain any answers in Remarks ) suMMARy OF FINDINGS - Attach sate map showing sampling point locations, transects, important features, etc.

Hydrophytic Vegetation Present?
Hydric Soil Present?
Wetland Hydrology Present?
Yes _:_
Yes Y
Yes --tNo- JNo
No
ls the Sampled Area
wlthin a Wetland? Yes- ro X
VEGETATION - Use scientific names of plants.

2. q

4. Tree Stratum (Plot size:

1. Saoljns/Shrub..jsl[alum

1. (Plot size:

Absolute Dominant lndicator
% Cover Soecies? Status
-
I",", *ro
-
*oro
5o Y [ACr.r 2G Y (Acu

2. 3.

4. 5.

Percent of Dominant Species . r,
That Are OBL, FACW or FAC: '' / r.' (NB)
Dominance Test worksheet:

Number of Dominant Species
That Are OBL, FACW Or FAC:

Total Number of Dominant
Species Across All Strata:
(A)
(B)
I
b
Prcvalence !ndex worksheet:

Total % Cover of: Multiplv bv:

OBLspecies to x'l= to'
FACW sDecies x2=
FAC species 7 o x3=
---@- FACU species 7O xq,= LB o
UPlspecies x5=-
ColumnTotals: /ae 1A1 q|t'a
@)
Prevalence lndex = B,1Ar= L'l

3. Q|9 QPLa\qJu< f ra +-oi s,r fl+ G
a.---GJ- trs l'n*lrr,^, 5 ?AL
5 ?AC
lO oB t10.

11. Woodv Vine Stratum (Plot size: )
I Oo = Total Cover
"o,/t
o
-=-*",.
% Bare Ground in Herb Stratum

5. 6.

7. 8.

9. Hydrophytic Vegetation lndicatoF:
_ 1 - Rapid Test for Hydrophytic Vegetation
_ 2 - Dominance Test is >50o/o
-
3 - Prevalence lndex is s3.01
-
4 - Morphological Adaptationsr (Provide supporting
data in Remarks or on a separate sheet)
-
5 - Wetland Non-Vascular Plantsl
-
Problematic Hydrophytic Vegetationr (Explain)
'lndicators of hydric soil and wetland hydrology must
be present, unless disturbed or problematic.

Hydrophytic
Vegetation
Present?
\.J
Yes No A'
Remarks:

US Army Corps of Engineers Western Mountains, Valleys, and Coast - Version 2.0

1. 2.

Depth . Matrix Redox Features (inches) @ Texture Remarks ]-O ? sfA 't/, $-".,s;,LTS_ G. ,,,
{"fB 1.sieri, ?O ?o
Hydric Soil lndicators: (Applicable to all LRRs, unless otherwlse noted.l _ Histosol (A1) _ Sandy Redox (S5)
. Histic Epipedon (A2) _ Stripped Matrix (56)
-
Black Histic (A3) _ Loamy Mucky Minerat (Fl) (excopt MLRA i) _ Hydrogen Sulfide (A4) _ Loamy Gteyed Matrix (F2)
_ Depleted Below Dark Surface (A11) _ Depleted Matrix (F3) _ Thick Dark Surface (A12) _ Redox Dark Surface (F6)
_ Sandy Mucky Mineral (Sl) _ Depleted Dark Surface (F7) _ Sandy Gleyed Matrix (S4) _ Redox Depressions (F8)
lndicators for Problemafic Hydric
_ 2 cm Muck (A10)
l( neO Parent Materiat (TF2)
_ Very Shattow Dark Surface (TF12)
_ Other (Explain in Remarks)
3lndicators of hydrophytic vegetalion and
wetland hydrology must be present,
unless disturbed or problematic.

Hydrlc Soil Present? v"" { No

HYDROLOGY
Primarv lndicators (minimum of one reouired: check all that aoolv) _ Surface Water (A't)
_ High Water Table (A2)
_ Saturation (A3)
_ Water Marks (Bl)
_ Sediment Deposits (82)
_ Drift Deposits (83)
_ Algal Mat or Crust (B4)
_ lron Deposits (85)
_ Surface Soil Cracks (86)
_ Water-Stained Leaves (89) (except
MLRA 1, 2,4d and 48)
_ Salt Crust (811)
_ Aquatic lnvertebrates (B13)
_ Hydrogen Sulfide Odor (Cl)
_ Oxidized Rhizospheres along Living Roots (C3)
_ Presence of Reduced lron (C4)
_ Recent lron Reduction in Tilted Soils (C6)
_ Stunted or Stressed ptants (D1) (LRR A)
SecondaN lndicators (2 or more reouired)
_ Water-Stained Leaves (89) (IUILRA 1,2,
44, and 48)
_ Drainage Pattems (B10)
_ Dry-Season Water Table (C2)
_ Saturation Visible on Aerial lmagery (C9)
_ Geomorphic Position (D2)
_ Shallow Aquitard (D3)
_ FAC-Neutrat Test (Dg)
_ Raised Ant Mounds (D6) (LRR A)
_ Frost-Heave Hummocks (D7) _ lnundation Visibte on Aeriat tmagery (87) _ Other (Explain in Remarks) _ Sparsely Vegetated Concave Surface (Bg)
Surface Water Present?
Water Table Present?
Saturation Present?
Yes
.
trto Y Depth (inches):
yes 'X No- Depth(inches): nYes X, No_ Depth(inches): /n Wetland Hydrology Present? t"" k No Describe Recorded Data
Western Mountains, Valleys, and Coast - Version 2.0
US Army Corps of Engineers
SOIL
ry;-
r"Tt""ii'Tll".l'Tit"""
- -
lluntains,
vareys, and coast Resion
lnvcor;^^.-,,. E-- // lnvestigator(s): ar-g.G*
R H -l;.---.-
samPrins Date:-5'7' a .l-- il:ilffi;:"** ;1 '##r'6:^ffi ":,;ilffim Arecrimaric/hyd."n i:b",I;TAre Vegetation ::trffi& , Soi, Arevesetarion-- .;;-- ;:il'::,,]i- sisniricanrvc,isturbed? - ll";= ,r'r*, *o,",nl;";#.;---
,* _-
^Jl],
jl":,i,*,;;;;# ;,.#:.:,,,.":i*",,.",";,:ll, "* *,"
, transects, imp6rtant features, etc.

I
;1o1,io1vti'-v*
.nYortc Soil present?
-_ No x..- Yes
r.ro T- Yes ^, -:- f,,ffi:",[#:i#""
ry**** (Prorsize:
)
!a-\ r.-1 b ++Y rru
a- ,-:--
10 -
r^lll r
. w,2 nsi s

10. 11.
% Bare Ground in Herb Stratum
^,
_....,.-,,vo I est WOTkShGE
i#iii;:"J3iH31j,:5:F[3,
JS1,I'#:f '^?"S[,T,
iffiil:"jBi:Ttilt:rFi:,
o
(A)
L
(B)
ula
OBL species
FACW species
FAC species
FACU species
UPL species
Column Totals:
---- x1=
--
--- X2= __
---- X3= .-
-- X4=
_-
-- X5=
--
r/A\
I _ I - Rapid Test for Hydrophytic Vegetation
-
2 - Dominance Test is >50%
-
3 - Prevalence lndex is s3.Or
-
4-Morphological AdaE
o ata in nl-m-a'i[s """,r#,,j::;fi?Jffi ,on,nn
_ 5 - Weiland Non_Vascular plantsr
;,:l:b,"r_:,ic Hydrophyric vesetarion, (Exptain)
,'H:jS[ :f, "l*:., :^gl :ld be presenr,
weil a nd hyd ro ro g y m usr unr6s, aisirrt"i ffiffiJ#liJ:

Hydrophytic
Vegetaflon
Present? yes_ t,lo I/
11 ,
I ',,.i tr, lsJ 4rva^l,s
?c.^'t,h 4!v.-\r^ al ,nl c,g
aErldrxs_ I ! ,
t't.. e ,\ C6+s do. l')?otVoe.; s ra,di<c..-a I AtU
51,,,t S,rrrl' {K_,^t, orrvrtll..'. ,, {.,1._d.<t r .Fr, ,..,rr.} ? (acu fAc -r--'
US Army Corps of Engineers Western Mountains, Valleys, and Coast - Version 2.0 Woodv Vine Stratum (plot size: I
1 Prevalence lndex = B/A =
,T 2 cm Muck (A10)
r-ll*;;y"**ffi6,,a
- liilt t*'lain in Remarks)
fo,*roo of hydrophytic vegeta$on and
"'"r^[o]no;ro;ology must be present'
-*
g--g? o'"0''
- x;fg,nlon rnz) _ ::X;'*:il"8?!,,g;l (except MLRA t)
=
#'*tlffirr*'" " -''#l,.ryiffffi,, \- iffir*ckyMin:larlsll -_ili;# I - ;;;;; orev"d Matdx (?
-
HydricSoll "tt*L
:-jj.-
ilS'ir,- rb" iay,r f,k +'
16 z, ti,eAo*
""^"^{cr\o^:

HYDROLOGY
\./
wetland HYdrologY Preent? Yes
-
No -4-
Secondarv lndicators (2 or more reouired)
a-*-r-a,r,ned Leaves (Bg) (MLRA 1' 2' *ffi;d
Leaves (Bs) (excePt
MLRA t' 2' 4A' and ttB)Surface Water (A1)
-- H,gn W.t"r Tabb (A2)
Saturation (A3)
Water Marks (B1)
Sediment Deposits (82)
Drift Deposits (83)
Algal Mat or Crust (B4)
L
-
lron Deposits (85)
Surface Soil Cracks (86)
- fnunOation Visible on Aerial lmagery (B7)
SP"rr"fV v"g"td"d C""*'" S'd'
4A, and 48)
Drainage Pattems (810)
Dry-season Water Table (C2)
- S.trr.tion Visibb on Aerid lmagery (Cg)
-- OeomotPnic Position (02)
-
Shallow Aquitard (D3)
-
FAC-Neutral Test (D5)
Raised Ant Mounds (DO) (LRR A)
-
FroslHeave Hummocks (D7)
Sa[ Crust (B11)
Aouatic lnvertebrates (Bl 3)
- Hvdrosen-S'*::::::ls ui,ins Roots (c3)
Oxidized RhizosPheres
Presence of Reducect lron (C4)
- *"*ril,"n Reduction in Tilled Soils (C6)
- ;;; or stressed Plants (D1) (LRR A)
Other (Explain in Remarks)
Surface Water Present?
Water Table Present?
Saturation Present? I::z[=filffi:3.-'T
US Army Corps of Engineers Weslern Mountains, Valleys, and Coasl - Version 2.0 ,-/
SamPting Potnt:
r
ProjecUSite:

WETLAND DETERMINATION DATA FORM -Western Mountains, Valteys, and Coast Region _./
L ^*Lrl'--* T; ^V bcitylcounty: Mendocino samprinsoa", ?n-27 ApplicanUOwner: State: CA Sampling ro,nr'E
lnvestigator(s): Estelle P' Clifton section, Township, nange, .S, 7 T.( t N \L\ E\^J Landform (hillslope, terrace, etc.): Local relief(concave, convex, none): h , ^{.- Slope (yo): O Subregion (LRR): at a9 .'t z iY- tong, - l-3. j S Zz-' o*r* n,I oE SoirMapunirName: e o/. <i // I a/^ 7 **",".**
Areclimatic/hydrologicconditionsonthesitetypical forthistimeofyear? Yes X No_ (lf no,explaininRemarks.) Are Vegetation
-,
Soil
-,
or Hydrology
-
significantly disturbed? Are "Normal Circumstances" present? yes I No Are Vegelation _, Soil or Hydrology _ naturally problematic? (lf needed, explain any answers in Remarks.) SUMMARY OF FINDINGS - Attach site map showing sampting point locations, transects, important features, etc. tt
,t,_
.1
I
I
!
!
Hydrophytic Vegetation Present?
Hydric Soil Present?
Wetland Hydrology Present?
Remarks:

Yes \ No- T--- yes Y No _
| ls the Sampled Area
y". j-_- No- l*itttin"w"tanaz v""il
VEGETATION - Use scientific names of plants.

Tree Stratum (Plot size:

1. Absolute Dominant lndicator
% Cover Soecies? Status
-
= rrr,".or;-
Total Cover

2. 3.

4. Saolinq/Shrub Stratum (Plot size:

1. Herb Stratum (Plot size: )

2. 3.

4. 5.
zS v F/cW
Dominance Test worksheet:

Number of Dominant Species .2_
That Are OBL, FACW or FAC: (A)
Tolal Numbef of Dominant .2
Species Across All Strata: > (B)
Fercent of Dominant Species , .a t/
Itat Are OBL, FACW or FAC: Q r ( t (NB)
Prevalence lndex worksheet:

Total o/o Cover of: Multiolv bv:

OBlspecies x1=_
FACwspecies x2= _
FAcspecies x3= _
FACUspecies x4= _
UPLspecies x5= _
Column Totals: _ (A) _
(B)
Prevalence lndex = B/A =
2 F4<-v)
t (ae
--

4. dt-aa+J -^s iCoL hg

6. 7.

8. 9.
v rAa
)S fficQ

5. Dinracr^s 1^llor.q,v 5 fA C

10. 11.

Woodv Vine Stratum (Plot size:

1. % =Totalcover qztf n
Hydrophytic Vegetation lndicatoB:
_ 1 - Rapid Test for Hydrophytic Vegetation
_ 2 - Dominance Test is >50%
-
3 - Prevalence lndex is s3.0i
_ 4 - Morphological Adaptationst (Provide supporting
data in Remarks or on a separate sheet)
_ 5 - Wetland Non-Vascular Plantsl
_ Problematic Hydrophytic Vegetationl (Explain)
tlndicators of hydric soil and wetland hydrology must
be present, unless disturbed or problematic.

Hydrophytic
Vegetation Present? ves X No- 2.
% Bare Ground in Herb Stratum
Remarks:

US Army Corps of Engineers Western Mountains, Valleys, and Coast - Version 2.0 No
SOIL
,I tl
Sampling Point:
dedtodocumenttheindicatororconfirmtheabsenceofindicato]s.) Depth
(inches) o-2L lD /R q /7-
Redox Features
Yo Texture Remarks
tTvoe: C=Concentration. D=Deoletion, RM=Reduced Matrix, CS=Covered orCoated Sand Grains. 2location: PL=Pore Lininq, M=Matrix Hydric Soll lndicators: (Applicable to all LRRS, untesa otherwlse noted.) lndicatorc for Problematlc Hydrlc Soils':
_ Histosol (A1)
-
Sandy Redox (S5)
-
2cm Muck (A10)
_ Histic Epipedon (A2) _ Stripped Matrix (56)
-
Red Parent Material (TF2)
_ Black Histic (A3) _ Loamy Mucky Mineral (F1) (except MLRA l) _ Very Shallow Dark Surface (TF12) _ Hydrogen Sulfide (A4) [ Loamy GEyed Matrix (F2)
-
Other (Explain in Remarks)
-
Depleted Below Dark Surface (A11) _ Depleted Matrix (F3) -
Thick Dark Surface (A12)
-
Redox Dark Surface (FG) tlndicators of hydrophytic vegetation and _ Sandy Mucky Mineral (Sl) _ Depleted Dark Surface (F7) wetland hydrology must be present, _ Sandy Gleyed Matrix (S4)
-
Redox Depressions (Fd) unless disturbed or problematic.

Type:

Depth (inches): Hydric Soil Present? Ves X No
-
Remarks: "'i"'-"'-' GIclrA o,olJr is g,ese^l .-l ;^ tL" , J +[ s,-{a6. ,

HYDROLOGY
wetland Hydrology lndicatons:

Primarv lndicalors (minimrrm of one reouired: check all thal annlv) Secondarv lndicators (2 or more reouired) _ Surface Water (Al) Water-Stained Leaves (89) (except _ Water-Stained Leaves (Bg) (MLRA 1, 2, _ High Water Table (A2) IUILRA 1, 2,4A, and 48) 4A, and 48) _ Saturation (A3) _ Salt Crust (B11) _ Drainage Patterns (810) _ Water Marks (Bl) _ Aquatic lnvertebrates (813) _ Dry-Season Water Table (C2) _ Sediment Deposits (82) _ Hydrogen Sulfide Odor (Cl) _ Saturation Visible on Aend lmagery (C9) _ Drift Deposits (83) _ Oxidized Rhizospheres along Living Roots (C3) _ Geomorphic Position (D2) -_ Algal Mat or Crust (84) _ Presence of Reduced lron (C4) _ Shallow Aquitard (D3) _
lron Deposits (85) _ Recent lron Reduction in Tilled Soils (C6) _ FAC-Neutral Test (D5) -
Surface Soil Cracks (86)
-
Stunted or Stressed Plants (Dl) (LRR A) _ Raised Ant Mounds (D6) (LRR A) _
lnundation Visible on Aerial lmagery (87) _ Other (Explain in Remarks) _ Frost-Heave Hummocks (D7) _ Sparsely Vegetated Concave Srfrace (B8)
Fielo observations:

Surface Water Present? Yes
-
*o y'
Depth (inches):

Water Table Present? Yes -X No
-
Depth (inches): t 1"
Saturation Present? Yes V No
-
Depth (inches): I >"
(includes capillary frinqe)
Wetland Hydrology Present? yes X No
Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available: - Remarks:

U, {-r- latlc i : lo cr.f./ i ,*,n clir,ls 1', 5c lru l-<- -l^lv.z.lcJ 'to a( J
US Army Corps of *gineers Western Mountains, Valleys, and Coast - Version 2.0 WETLAND DETERMINATION DATA FORM -Western Mountains, Valleys, and Coast Region Projecusite: 9a-Lrl''i^ t,-, L-* C" City/County:
g -t-Z z Sampling Date: "
ApplicanUOwner: '\ ll
Sec{ion, Township, Range:

State: I Sampling Point I2
(a-.1 f/E l\J RtE,.*) lnvestigato(s): Estelle P' Clifton Landform (hillslope, terrace, etc.): s r.. Jl t rlr€if Jr[( Local relief (concave, convex, none): crttco.tZ Slope (%): O Subregion (LRR):
-
Lat: Sq,!3j-1: tong: -l Li,3 tl2-o Datum: trlAD /3
Mendocino
soir rra-ap ui^n*^ NW ctassification:
arc .timetin / hvrtrotodic conditions on the site tvoical for thfs time of vear? Yes k No -
(lf no, explain in Remarl Areclimatic/hydrologicconditionsonthesitetypical forthl'stimeofyear? Yes l No- (lf no,explaininRemarks.) Are Vegetation _, Soil or Hydrology
-
significantly disturbed? Are "Normal Circumstances" present? Yes X No Are Vegetation
-,
Soil
-,
or Hydrology
-
naturally problematic? (lf needed, explain any ansu,ers in Remarks.) SUMMARY OF FINDIiIGS - Attach site map showing sampling point locations, transects, important features, etc.

Hydrophytic Vegetation Present?
Hydric Soil Present?
Wetland Hydrology Present?
Remarks:

Yes X No- I
Yes- Nol I lstheSamPledArea
v".- lloE l*ittrinawetlanoz Ye"- t{oVEGETATION - Use scientific names of plants.

Tree Stratum

1. {Plot size: )
Absolute Dominant lndicator
% Cover Soecies? Status
-il",*ro
= Total Cover
2 5 V fActt
70 {"{a- ?D Y U' to'b ogLTotal Cover

2. I

4. Saolinq/Shrub Stratum

1. (Plot size: )

2. 3.

4. 5.

Herb Stratum

1. 2.

3. 4.

5. 6.

7. 8.

9. 10.

11. Woodv Vine Stratum (Plot size: )
T*ou", x/s.L
't.

2. % Bare Ground in Herb Stratum
^nn.h^.

Dominance Tgst worksheet:

Number of Dominant Species
That Are OBL, FACW or FAC:

Total Number of Dominant
Species Across All Strata:

Percent of Dominant Species
That Are OBL, FACW, or FAC: (A/B)
2_
(A)
9 (B)
a1 /.

Prevalence lnder worksheet:

Tolal o/n Cover of Multiolv bv:

OBLspecies x1=-
FACW species x2=
-
FACspecies x3=-
FACUspecies x4=
-
UPL species
Column Totals:
-
(A)
-
(B)
Prevalence lndex = B/A =
Hydrophytic Vegetation lndicatons:
-
1 - Rapid Test for Hydrophytic Vegetation
_ 2 - Dominance Test is >50%
-
3 - Prevalence lndex ls s3.01
-
4 - Morphological Adaptationsr (Provide supporting
data in Remarks or on a separate sheet)
-
5 - Wetland Non-Vascular Plantst
-
Problematic Hydrophytic Vegetationl (Explain)
llndicators of hydric soil and wetland hydrology must
be present, unless disturbed or problematic.

Hydrophytic t /
V€getatlon X
Present? Yes- NoRemarks:

Western Mountains, Valleys, and Coast - Version 2.0 US Army Corps of Engineers Sampling Point: t2
Depth Matrix
(inches)
= Color (moist) o/o
o-'t I olR q/z
1 'q (ar,rt ,/(z b
t"/E a/s 5D
tolR 3/t 7o jjiinTv 6
Hydric Sol! lndlcators:
_ Histosol (Al)
_ Histic Epipedon (A2)
_ Black Histic (A3)
_ Hydrogen Sulfide (A4)
_ Depleted Below Dark Surface (Al 1)
_ Thick Dark Surface (A12)
_ Sandy Mucky Minerat (Sl)
_ Sandy Gleyed Matrix (S4)
(Applicable to all LRRS, unless otherwlse noted.)
_ Sandy Redox (S5)
_ Stripped Matrix (36)
_ Loamy Mucky Minerat (F1) (oxcept MLRA i)
_ Loamy Gleyed Matrix (F2)
_ Depleted Matrix (F3)
_ Redox Dark Surface (F6)
_ Depleted Dark Surface (F7)
_ Redox Depressions (F8)
_ 2cm Muck (A10)
_ Red Parent Materiat (TF2)
_ Very Shallow Dark Surface (TF12)
_ Other (Explain in Remarks)
3lndicators of hydrophytic vegetation and
wetland hydrology must be present,
unless disturbed or problematic.

Hydric Soil Present? Yes
-
tto X

HYDROLOGY
Primarv lndicators (minimum of one reouired: check all that aoolv) _ Surface Water (A1)
_ High Water Tabte (A2)
_ Saturation (A3)
_ Water Marks (Bl)
-_ Sediment Deposits (B2)
_ Drift Deposits (83)
_ Algal Mat or Crust (84)
_ lron Deposits (BS)
_ Surface Soil Cracks (86)
_ lnundation Visible on Aerial lmagery (87)
_ SparselyVegetated Concave Surface (Bg)
_ Water-Stained Leaves (89) (except
ilLRA 1,2,1A"and1Bl
_ Salt Crust (B11)
_ Aquatic lnvertebrates (813)
_ Hydrogen Sutlide Odor (Cl)
_ Oxidized Rhizospheres atong Living Roots (C3)
_ Presence of Reduced lron (C4)
_ Recent lron Reduction in Tiiled Soits (C6)
_ Stunted or Stressed ptants (Dl) (LRR A)
_ Other (Exptain in Remarks)
Secondarv lndicators (2 or more reouired)
_ Water-Stained Leaves (89) (ItlLRA 1, 2,
4A, and 48)
_ Drainage Patterns (810)
_ Dry-Season Water Tabte (C2)
_ Saturation Visible on Aeriat tmagery (C9)
_ ceomorphic Position (D2)
_ Shallow Aquitard (D3)
_ FAc-Neutral Test (D5)
_ Raised Ant Mounds (D6) (LRR A)
_ Frost-Heave Hummocks (D7)
Surface Water Present? yes _ No _ Depth (inches): t t
Water Tabte Present? yes X No _ Depth (inches): -{
Saturation Present? yes X No_ Depfh linchesj: Wr- Wetland Hydrotogy Present? yes no X Describe Recorded Data 6tr""
US Army Corps of Engineers Weslern Mounlains, Valleys, and Coast - Version 2,0 Hydrophytic Vegetation present? Ves V No _
Hydric Soil Present? yes _ ruo \
Wetland Hydrology Present? yes _ No X
ls the Sampled Area
within a Wetland? Yes- rto ,X
R;T* l^^ €-rzst n6rfl *w11 4r c<
Are Vegetation _, Soil _, or Hydrology _ significanuy disturbed? Are Vegetation _, Soil _, or Hydrology _ naturally problematic? Are "Normal Circumstances" present? yes k No
(lf needed, explain any ans\ rers in Remarks.)
la
SUMMARY oF FINDINGS - Attach site map showing sampling point locataons, transects, important features, etc.

VEGETATION - Use scientific names of plants.

I vve^2trii
Saplino/Shrub Stratum (Plot size: -
)

3. R, A.r ut.L'Y ,a. c -t 5
% Cover Species? Status
So y facA
11" V Al
)-5 v rlcd
.L qg
= Tot rcor", f/a
-7+ =TotalCoverTT/,, /
teo Y flC
4e \r Fqc tl
30 " €ac
l?O =TolalCovets.//jtt Woodv Vine Stratum (Plot size:

1. % Bare Ground in Herb Stratum
rl

2. R^br"S tar g i^*5
Percent of Dominant Species
- ^ \,
That Are OBL, FACW, or FAC: J U /, (A/e,1
Number of Dominant Species
That Are OBL, FACW, or FAC:

Tolal Number of Dominant
Species Across All Strata:

OBL species
FACW species
FAC species
FACU species
UPL species
Column Totals:
_ 1 - Rapid Test for Hydrophytic Vegetation
_ 2 - Dominance Test is >50%
_ 3 - Prevalence lndex is s3.0i
_ 4 - Morphologicat Adaptationsl (provide supporting
data in Remarks or on a separate sheet)
_ 5 - Wetland Non-Vascular plantsl
_ Problematic Hydrophytic Vegetationl (Explain)
tlndicators of hydric soil and wefland hydrology must
be present, unless disturbed or problematic.
''US Army Corps of Engineers Western Mountains, Valleys, and Coast - Version 2.0 (Plot size: )
Herb Stratum (Plot size:

Hydrophytic
Vegetation
Present? Yes
samplins point 13
SOIL
e absence of indicators')
Depth Texture Remarks
D=Deoletion. RM=Rectuced Matrix, CS=Covered or Coated Sand Grains. 2location: lTvne C=C PL=Pore Lining, M=Matrix:

Hydric Soil lndicators:
_ Histosol (Al)
_ Histic Epipedon (A2)
_ Black Histic (A3)
_ Hydrogen Sulfide (A4)
_ Depleted Below Dark Surface (Al 1)
_ Thick Dark Surface (A12)
_ Sandy Mucky Mineral (S1)
_ Sandy Gleyed Matrix (S4)
(Applicable to all LRRS, unless otherwise noted.) lndicatols for Problematic Hydric Soils':
_ 2 cm Muck (A10)
_ Red Parent Material (TF2)
_ Very Shallow Dark Surface (TF12)
_ Other (Explain in Remarks)
3lndicators of hydrophytic vegetation and
wetland hydrology must be present,
unless disturbed or problematic.

Sandy Redox (S5)
Stripped Matrix (56)
Loamy Mucky Mineral (F1) (except MLRA 1)
Loamy Gleyed Matrix (F2)
Depleted Matrix (F3)
Redox Dark Surface (FO)
Depleted Dark Surface (F7)
Redox Depressions (F8)
strictive Layer (if present):

Type:

Depth (inches): Hydric Solt Preaent? Yes
-
f,fo X
Remarks:
a" ,!"'. |L
cl"'ll.''' Al *rsJ' '?("

HYDROLOGY
Wetland Hydrology lndicators:

Primarv lndicators (minimum of one reouired: check all that aDplv) Secondarv lndicators bor more required) _ Surface Water (A1) _ Water-stained Leaves (Bg) (excdPt -
Water-Stained Leaves (Bg) (MLRA l, 2'
-
High Water Table (A2) IIILRA {, 2,4A and 48) 4A, and 48) _ Saturation (A3) _ Salt Crust (81'l)
-
Drainage Patterns (810)
_ Water Marks (B1) _ Aquatic lnvertebrates (B13)
-
Dry-Season Water Table (C2)
_ Sediment Deposits (82) _ Hydrogen Sulfide Odor (C1)
-
Saturation Visible on Aerial lmagery (Cg)
_ Drift Deposits (83) Oxidized Rhizospheres along Living Roots (C3) -
Geomorphic Position (D2)
_ Algal Mat or Crust (84) _ Presence of Reduced lron (C4) -
Shallow Aquitard (D3)
_ lron Deposits (85) _ Recent lron Reduction in Tilled Soils (C6) -
FAC-Neutral Test (D5)
_ Surface Soil Cracks (86) _ Stunted or Stressed Plants (Dl) (LRR A) -
Raised Ant Mounds (D6) (LRR A)
_
lnundation Visible on Aerial lmagery (B7) _ Other (Explain in Remarks) -
Frost-Heave Hummocks (D7)
_ SparselyVegetated Concave Surface (88)
Field Observations:

Surface Water Present? Yes
-
No
-
Depth (inches):

Water Table Present? Yes {- No
-
Depth (inches):

Saturation Present? yes
-X- No
-
Depth (inches): Wetland Hydrotogy Pr6ent? Yes
-
ffo X
Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:

Remarks:

US Army Corps of Engineers Western Mountains, Valleys, and Coast - Version 2.0 ;;wll io
Revised Draft CEQA Initial Study
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025

A P P E N D I X D
M i t i g a t i o n a n d M o n i t o r i n g P r o g r a m ( M M R P ) Mitigation Monitoring and Reporting Program
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 1

MITIGATION MONITORING AND REPORTING

PROGRAM
Public Resources Code, Section 21081.6 (Assembly Bill 3180) requires that mitigation measures identified in environmental review documents prepared in accordance with California Environmental Quality Act (CEQA) are implemented after a project is approved.

Therefore, this Mitigation Monitoring and Reporting Program (MMRP) has been prepared to ensure compliance with the adopted mitigation measures during the implementation of the Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment (Project). The City of Willits is the agency responsible for implementation of the mitigation measures identified in the Initial Study.

This MMRP provides the City of Willits with a convenient mechanism for quickly reviewing all the mitigation measures including the ability to focus on select information such as timing. The MMRP includes the following information for each mitigation measure:

The phase of the project during which the required mitigation measure must be implemented;
The phase of the project during which the required mitigation measure must be monitored;
The enforcement agency; and
The level of significance after mitigation.

The MMRP includes a checklist to be used during the mitigation monitoring period. The checklist will verify the name of the monitor, the date of the monitoring activity, and any related remarks for each mitigation measure.

Mitigation Monitoring and Reporting Program
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 2
Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Phase Monitoring Phase
Enforcement
Agency
Level of
Significance After
Mitigation
Verification of
Compliance
Initial Date
Biological Resources
BIO-1: Prior to the start of construction, areas of the Site associated with listed species and sensitive habitats and that are not proposed to be impacted shall be identified and designated as Environmentally Sensitive Areas (ESAs) using flagging, high-visibility orange fencing, and/or silt fencing. This applies specifically to areas with Baker’s meadowfoam, North Coast semaphore grass, Davy’s semaphore grass, Blue Wildrye Prairie, Valley Oak Woodland, Valley Oak Riparian Woodland, and wetlands. ESAs shall be shown on design plans or maps for the proposed project, to be provided to construction personnel. The ESA flagging/fencing shall remain in place throughout the duration of construction activities to prevent the encroachment of construction equipment/personnel into sensitive areas. To the extent feasible, construction activities shall be located outside of any designated ESA.

Prior to
Construction
During
Construction
City of Willits Less than
significant
BIO-2: Barriers shall be installed around the limits of listed species and sensitive habitats that may be impacted by unintended encroachment during operation of the proposed project and that are not easily identified, including Baker’s meadowfoam, North Coast semaphore grass, Davy’s semaphore grass, Blue Wildrye Prairie, and wetlands. These barriers shall be installed in a way that would be clearly identified by employees but would not interfere with wildlife movement.

Post Construction Post Construction City of Willits Less than significant
BIO-3: Construction activities for the proposed project shall be conducted, if possible, outside of the nesting seasons for white-tailed kite (January 15 to August 15) and yellow warblers (March 15 to August 15) to avoid impacts to these species. If construction activities begin during the nesting season, a qualified biologist shall conduct a pre-construction survey for active nests in suitable nesting habitat within 500 feet of the construction area no more than seven (7) days prior to the initiation of construction. If no active nests are identified during the pre-construction survey, no further mitigation is necessary. If at any time during the nesting season construction stops for a period of seven (7) days or longer, a supplemental pre-construction survey shall be conducted prior to construction resuming.

If active nests are found within the construction footprint or immediately adjacent to construction activities within the project area, the biologist shall establish a species-appropriate buffer or exclusion zone around the nest (approximately 500 feet for white-tailed kites and 100 feet for yellow warblers) and/or operational restrictions within the buffer in consultation with the California Department of Fish and Wildlife (CDFW). Construction activities shall avoid nest buffers until the qualified biologist determines that the birds have fledged and are no longer reliant upon the nest or parental care for survival. The qualified biologist may modify these buffers, in consultation with CDFW, depending upon the species, nest location, and existing visual buffers.

Prior to
Construction,
During
Construction
Prior to
Construction,
During
Construction
City of Willits Less than
significant
Mitigation Monitoring and Reporting Program
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 3
Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Phase Monitoring Phase
Enforcement
Agency
Level of
Significance After
Mitigation
Verification of
Compliance
Initial Date
If construction activity is required within the established buffer, the qualified biologist shall be consulted prior to beginning construction activities within this area. If the qualified biologist determines that the activity would impact the nest, the qualified biologist shall have the authority to stop work. If the qualified biologist determines that the activity would not disturb the nest, construction may continue under supervision of the qualified biologist or designee.

BIO-4: In the unlikely event that an American badger den (evidenced by a large mound of dirt piled outside an excavated den) is encountered during construction of the proposed project, construction work shall halt in the vicinity of the den, a qualified biologist shall evaluate the potential den site, and CDFW shall be notified if the hole is determined to be a potential American badger den. A 100-foot no-work buffer shall be established around occupied maternity dens throughout the puprearing season (February 15 through July 1) and a 15- foot no-work buffer around occupied dens during other times of the year. If nonmaternity dens are found and cannot be avoided during construction activities, they shall be monitored by a qualified biologist for badger activity. If the qualified biologist determines that dens may be occupied, passive den exclusion measures shall be implemented for three (3) to five (5) days to discourage the use of these dens prior to disturbance activities during construction.

Prior to
Construction,
During
Construction
Prior to
Construction,
During
Construction
City of Willits Less than
significant
BIO-5: Before construction activities begin, a qualified biologist shall conduct an education program for all construction personnel. The training shall include a description of special status species, including State-listed species and associated habitats with potential to occur in the study area; an explanation of the status of these species and their protection under the California Endangered Species Act; the measures to conserve listed species and their habitats as they relate to the work being done; and Environmentally Sensitive Areas (ESAs) to be avoided during construction. A fact sheet conveying this information will be prepared and distributed to all construction crews. Upon completion of the program, personnel shall sign a form stating that they attended the program and understand the mitigation measures.

Prior to
Construction
Prior to
Construction
City of Willits Less than
significant
BIO-6: The project proponent shall offset the removal of mature oak trees, defined as trees greater than 12 inches in diameter at DBH, through one or more of the oak woodland mitigation alternatives in PRC §21083.4, which may include conserving oak woodlands through the use of conservation easements, planting an appropriate number of trees, removing invasive species encroaching upon oak tress to be retained, contributing funds to the Oak Woodlands Conservation Fund, or other mitigation measures developed by the City, if any.

Prior to the issuance of a building and/or grading permit by the City and the start of construction, an Oak Mitigation and Monitoring Plan (Oak MMP) shall be prepared by a certified arborist, registered professional forester, botanist, or landscape architect. The Oak MMP shall be prepared to satisfy the standards of PRC §21083.4 and shall include the following elements, at a minimum: selected Prior to
Construction, Post
Construction
Post Construction City of Willits Less than
significant
Mitigation Monitoring and Reporting Program
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 4
Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Phase Monitoring Phase
Enforcement
Agency
Level of
Significance After
Mitigation
Verification of
Compliance
Initial Date
mitigation alternative(s) pursuant to PRC §21083.4; a map showing the location of all oak trees 5 inches or more DBH and all oak trees 12 inches or more DBH planned for removal; oak tree protection measures for oak trees to be retained with 20 feet of the construction area; and details related to on-site mitigation, if proposed. For on-site mitigation, the following information shall be provided:
proposed mitigation ratio; description and size of the area for replanting; planting techniques; maintenance and monitoring activities and schedule; irrigation requirements; success criteria; reporting plan and schedule; and remediation measures. Success criteria may consider factors such as relative cover of established oak woodland habitat, height of planted trees, and/or other relevant criteria as determined in the Oak MMP. The Oak MMP shall be submitted for review and approval by the City’s Community Development Director or his/her designee.

BIO-7: Permanent impacts to the Blue Wildrye Prairie community shall be compensated for through on-site revegetation, invasive species removal from within the Blue Wildrye Prairie community to be maintained, and/or other measures as deemed appropriate in consultation with CDFW. Should on-site revegetation be proposed, portions of the Site shall be revegetated with a native seed mix that includes Blue wildrye (Elymus glaucus). Revegetation shall occur at a minimum ratio of 2.6 to 1, or as otherwise required by CDFW, to compensate for permanent impacts. Revegetation shall occur within areas of the Site deemed appropriate for Blue wildrye (Elymus glaucus). - Commercially available native grasses shall be used to revegetate.

These grasses include but are not limited to: Blue wildrye (Elymus glaucus), California brome (Bromus sitchensis var. carinatus), California fescue (Festuca californica), Pine bluegrass (Poa secunda), and California oatgrass (Danthonia californica).
- A native grass seed blend such as Holdfast Native Blend from LeBallister’s can be purchased and used as a viable option for revegetation plans. This mix consists of California brome, Blue wild rye (Elymus glaucus), three weeks fescue (Festuca microstachys), California poppy (Eschscholzia californica), and California native lupines (Lupinus spp.). This seed mix conforms to the standard practice of using grasses, legumes, and wildflowers in combination for erosion control and revegetation plans.
- A qualified botanist or landscape architect shall advise the field crew on seeding rate and dispersal technique. Broadcast seeding is an effective way to reclaim bare areas and should be done just prior to the autumn rains. If insufficient rain is in the forecast when seeding can occur, irrigation must be used to gently water in the seeds for the first season.

Post Construction Post Construction City of Willits Less than significant
BIO-8: Due to the proposed impacts to on-site wetlands and drainage ditches, the project proponent shall obtain a Section 404 CWA permit through USACE for impacts to waters of the United States and a Section 401 WQC from the NCRWQCB, if deemed necessary by these resource agencies. If required, these Prior to
Construction, Post
Construction
Post Construction City of Willits Less than
significant
Mitigation Monitoring and Reporting Program
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 5
Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Phase Monitoring Phase
Enforcement
Agency
Level of
Significance After
Mitigation
Verification of
Compliance
Initial Date
permits shall be obtained prior to issuance of grading permits for construction activities in or adjacent to the on-site wetlands and drainage ditches, as determined through consultation with the USACE and NCRWQCB.

The project proponent shall ensure that the design of the proposed project would not result in a loss of functions and values of waters of the United States or State through impact avoidance, impact minimization, and/or compensatory mitigation for the impact, as determined by the resource agencies. The project proponent shall design the proposed project to limit the obstruction of and human intrusion into the riparian area of the on-site wetlands and drainage ditches, to the extent feasible. If it is determined, through obtaining an Approved Jurisdictional Determination through the USACE, that the aquatic resource features at the Site are not jurisdictional under the CWA, then the Section 404 CWA permit and Section 401 WQC may not be required.

Compensatory mitigation may consist of:

1. Providing on-site compensatory mitigation through an aquatic resource restoration (which may include removal of invasive species and/or native species planting), establishment, enhancement, and/or preservation activity in a location at or adjacent to the impact site;

2. Providing off-site compensatory mitigation through an aquatic resource restoration, establishment, enhancement, and/or preservation activity at another location, usually within the same watershed as the permitted impact;

3. Obtaining credits from a mitigation bank; and/or

4. Making a payment to an in-lieu fee program that would conduct wetland, stream, or other aquatic resource restoration, creation, enhancement, or preservation activities. The project proponent retains responsibility for the implementation and success of the mitigation project.

Evidence of compliance with this mitigation measure shall be provided to the City’s Community Development Department prior to initiating construction activities in or adjacent to the on-site wetlands and drainage ditches.

Cultural Resources
CUL-1: In the event archaeological resources or cultural resources, including human remains, are inadvertently unearthed or discovered during construction, the contractor shall immediately halt all grading/land-clearing activities and contact a qualified archaeologist. Project personnel shall not collect the potential resources. All activity in the vicinity of the resources shall cease until a qualified archaeologist can evaluate it. If the qualified archaeologist determines that the resources may be significant, they shall notify the City’s Community Development Department and develop an appropriate treatment plan for the resources. The archaeologist shall consult with Native American representatives in determining appropriate treatment for prehistoric or Native American cultural During
Construction
During
Construction
City of Willits Less than
significant
Mitigation Monitoring and Reporting Program
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 6
Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Phase Monitoring Phase
Enforcement
Agency
Level of
Significance After
Mitigation
Verification of
Compliance
Initial Date
resources. In considering any suggested mitigation proposed by the archaeologist, and Native American representative where applicable, the City’s Community Development Department will determine whether avoidance is necessary and feasible in light of factors such as the nature of the find, project design, costs, and other considerations. If avoidance is infeasible, other appropriate measures (e.g., data recovery) will be instituted. Work may proceed in other parts of the project area while mitigation for cultural resources is being carried out.

CUL-2: If human remains are encountered on-site, all work must stop in the immediate vicinity of the discovered remains and the Mendocino County Coroner and a qualified archaeologist shall be notified immediately so that an evaluation can be performed. If the remains are deemed to be Native American and prehistoric, the NAHC shall be contacted by the Coroner so that a “Most Likely Descendant” can be designated and further recommendations regarding treatment of the remains can be provided.

During
Construction
During
Construction
City of Willits Less than
significant
CUL-3: Any identified cultural resources shall be recorded on DPR 523 historic resource recordation forms by a qualified archaeologist, available online from the Office of Historic Preservation’s website:
http://ohp.parks.ca.gov/default.asp?page_id=1069.

During
Construction
During
Construction
City of Willits Less than
significant
Geology and Soils
GEO-1: In the event that paleontological resources, including individual fossils or assemblages of fossils, are encountered during construction activities all ground disturbing activities shall halt, and the City’s Community Development Department shall be contacted. Additionally, a qualified paleontologist shall be procured to evaluate the discovery and make treatment recommendations.

During
Construction
During
Construction
City of Willits Less than
significant
Hazards and Hazardous Materials
HAZ-1: Prior to operation of the project and future proposed projects, the project proponent shall prepare an EAP to the satisfaction of the Little Lake Fire District.

The EAP shall describe plans and preparedness for emergency response. This includes a list of emergency contacts, access requirements, evacuation routes and procedures, employee trainings, deck orientation maps, adequate water supply, and on-site firefighting equipment. Firefighting equipment to keep on-site for use in emergencies may include but not be limited to a water truck, fire extinguishers, fire tools, and a portable foaming fire suppression system. The EAP shall also include fire prevention and mitigation strategies, including identification of potential fire hazards, general housekeeping, and required training. Implementation of the EAP shall provide employees with the ability to put out a 10-foot by 10-foot, or equivalent, spot fire should the need arise. For uses involving bark storage, a Bark Management Plan shall be included as part of the EAP. The Bark Management Plan shall include general management techniques, strategies to reduce the risk of bark piles catching on fire, response protocols, and other details as required by the Little Lake Fire District.

Prior to Operation Prior to Operation City of Willits Less than significant
Mitigation Monitoring and Reporting Program
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 7
Mitigation Monitoring and Reporting Program
Mitigation Measure
Implementation
Phase Monitoring Phase
Enforcement
Agency
Level of
Significance After
Mitigation
Verification of
Compliance
Initial Date
Noise
NOI-1: To reduce the possibility of the construction noise becoming an annoyance to existing residences near the Site, exterior construction activity shall be confined to between the hours of 7:00 a.m. and 7:00 p.m. Monday through Saturday, or as approved by the City. Additionally, construction activities shall utilize quiet models of air compressors and other stationary noise sources where technology exists and use mufflers on all internal combustion engine-driven equipment.

During
Construction
During
Construction
City of Willits Less than
significant
NOI-2: To ensure future typical industrial facilities that would be allowed under the land use and zoning designations of M-G and MH do not generate noise in excess of standards established in the Willits General Plan (1992), City Code (2021), and other applicable noise standards, a noise assessment shall be conducted to analyze noise that may be generated by the project. If the noise assessment concludes that noise generated by the project would exceed standards established in the Willits General Plan (1992), City Code (2021), and other applicable noise standards, abatement measures shall be incorporated into the project design to reduce noise to below these standards.

Prior to
Construction of
Future Typical
Industrial Facilities
Prior to
Construction of
Future Typical
Industrial Facilities
City of Willits Less than
significant
Revised Draft CEQA Initial Study
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025

A P P E N D I X E
F o c u s e d T r a n s p o r t a t i o n I m p a c t S t u d y 490 Mendocino Avenue, Suite 201 Santa Rosa, CA 95401 707.542.9500 w-trans.com SANTA ROSA • OAKLAND
November 29, 2023
Mr. Dee Sanders
Sanhedrin Timber Company, LLC
P.O. Box 249
Weaverville, CA 96093
Focused Transportation Impact Study for the Sanhedrin Timber Company Entitlements Project
Dear Mr. Sanders;
W-Trans has completed a focused analysis of the potential transportation impacts associated with the proposed expansion of an existing lumber yard to encompass two adjacent parcels, including the Quail Meadows site in the City of Willits.

Existing Conditions
The study area consists of North Highway 101 (North Main Street) in the City of Willits. North Highway 101 generally runs north-south through the center of the City of Willits. Along the project frontage the road has a two-way left-turn lane in addition to two 11-foot travel lanes. The posted speed limit is 35 mph.

Project Description
The proposed project would nominally expand operation of the existing North Fork Lumber log yard on Casteel Lane to include two adjacent parcels, APN 108-040-11 (Quail Meadows) and 108-040-18. The project would require a change in the land use and zoning for both project parcels from Commercial General (C-G) and Community Commercial (C1) to Industrial General (M-G) and Heavy Industrial (MH) respectively.

The expanded log yard is intended to support local timber harvesting operations and increase log purchasing and storage capacity in the region. The proposed expansion would reduce crowding on the existing lumber yard site and enable trucks to circulate more easily as well as providing additional log storage for the mill operations. Development would generally consist of clearing the site and constructing irrigation ponds, log yards and internal roadways.

Access to the site would be via the existing driveway on Casteel Lane as well as the driveway for the Quail Meadows site on North Main Street. Three culverts would be constructed to enable traffic to circulate between the two project parcels and the existing log yard to the south.

Trip Generation
Truck volumes peak between May 15 and November 15. During this period, there are currently and would continue to be 40 to 60 inbound log trucks per day, with occasional days of 65 to 70 trucks; in addition, there are typically 15 to 20 outbound lumber trucks per day and occasional days with as many as 25 trucks.

From November 15 through May 15, the volume of inbound log trucks would continue to be considerably lower, with occasional spikes of up to 25 trucks per day. There would be an estimated 25 to 30 outbound trucks loaded with logs each day.

Mr. Dee Sanders Page 2 November 29, 2023
The proposed expansion of the yard would not change the number of trucks entering or leaving on peak days. Rather, it would allow a more consistent schedule of deliveries and shipments over the course of the year, dampening some of the variance between peak days and low-volume days.

From May 15 through November 15 the project would operate five to six days per week, typically from 6:00 a.m. to 5:00 p.m., and 5:30 a.m. to 7:00 p.m. at peak delivery times. During the remainder of the year, operation would be five days per week or less, from 7:00 a.m. to 4:00 pm.

Trip Distribution
The site is approximately one mile south of the North Main Street exit from US 101. As US 101 is the main route through Mendocino County, it is assumed trucks will primarily head north on Main Street to access US 101 to avoid going through the City of Willits.

Zoning Change
Consideration was given to the potential change in trip generation that could be expected due to the proposed rezoning of the 10.6-acre Quail Meadows site from Commercial to Light Industrial. Assuming that building sizes per acre would be relatively equal regardless of the use, trip generation rates for various uses were obtained from the Trip Generation Manual, 11th Edition, Institute of Transportation Engineers, 2021.

As shown in Table 1, the rates for industrial types of uses (the 100-series) are substantially lower than those for office, retail, or service uses. While rates are available for many more land uses, the sample shown is indicative of the various categories of use. In general, the industrial uses would need to have floor areas about three times higher than the least-intensive commercial uses.

Table 1 – Trip Generation Rate Comparison
Land Use Daily Trips AM Peak Hour PM Peak Hour
General Light Industrial (LU #110) 4.87 0.74 0.65
Manufacturing (LU #140) 4.75 0.68 0.74
Warehousing (LU #150) 1.71 0.13 0.18
General Office Building (LU #710) 10.84 1.52 1.44
Building Materials/Lumber Store (LU #812) 17.05 1.59 2.25 Hardware/Paint Store (LU #816) 8.07 0.92 2.98
Automobile Sales (LU #840) 27.84 1.86 2.42
Marijuana Dispensary (LU #882) 211.12 10.54 18.92
High-Turnover (Sit-Down) Restaurant (LU #932) 107.20 9.57 9.05 Automobile Parts and Service Center (LU #943) 16.60 1.91 2.06 Note: All rates are in trips per thousand square feet
Based on the information shown above, it is reasonable to anticipate that the change in land use, even if redeveloped rather than being used as proposed for an extension of an existing use, would result in less traffic than would be anticipated with the existing zoning.

Mr. Dee Sanders Page 3 November 29, 2023
Access and Circulation
Access Analysis
The project site would be served by two existing access points. The existing lumber operation takes access from North Main Street via Casteel Lane. The project would introduce a new access point to the site through a connection to the Quail Meadow site, which has an existing driveway that connects to North Main Street.

There is an existing two-way left-turn lane on North Main Street that can be used for traffic inbound at Casteel Lane. As the northerly driveway on the Quail Meadow site is not served by this two-way left-turn lane, the need for a left-turn lane for inbound travel was evaluated based on criteria contained in the Intersection Channelization Design Guide, National Cooperative Highway Research Program (NCHRP) Report No. 279, Transportation Research Board, 1985, as well as an update of the methodology developed by the Washington State Department of Transportation and published in the Method For Prioritizing Intersection Improvements, January 1997. The NCHRP report references a methodology developed by M.

D. Harmelink that includes equations that can be applied to expected or actual traffic volumes to determine the need for a left-turn pocket based on safety issues.

The log yard receives an average of 55 truckloads of logs daily for six months of the year and approximately 10 loads the other six months, for an annual average of 33 trucks entering the site daily. Given the ninehour workday a maximum of five trucks during a single hour would be expected. Because trucks require more space on the roadway and more time to make movements, a vehicle equivalency of three passenger vehicles per truck was assumed, translating the five inbound trucks to 15 inbound vehicle movements. An additional two trips were assumed for employees or other vehicles for 17 total inbound trips in an hour.

Assuming that trucks would come from US 101, it is likely that many of the drivers would enter via the first driveway they encounter, or the one at Quail Meadow. Of the 17 total inbound trips, 15 were assumed to occur at the Quail Meadow driveway. Counts for North Main Street obtained on April 26, 2023, were used to determine if there is a need for a left-turn lane. Based on these current counts and the project’s trip generation, a left-turn pocket is not warranted. Copies of the counts and warrant spreadsheets are enclosed.

Sight Distance
Sight distance along North Highway 101 at the project driveways was evaluated based on sight distance criteria contained in the Highway Design Manual published by Caltrans. The recommended sight distances for driveways are based on stopping sight distance, with approach travel speeds used as the basis for determining the recommended sight distance.

For the posted speed limit of 35 mph, 250 feet of sight distance is needed. From the northern driveway, sight lines extend more than 300 feet in both directions. At the existing southern driveway there are clear sight lines for more than 500 feet in either direction. Sight lines are therefore adequate at both driveways.

Emergency Response
On-site circulation was reviewed using the site plan provided. As the site has been laid out for large logging trucks, it is anticipated that all types of vehicles, including emergency responders, would be able to adequately navigate the site.

Mr. Dee Sanders Page 4 November 29, 2023
Vehicle Miles Traveled (VMT)
The Mendocino Council of Governments (MCOG) has adopted a regional baseline VMT study based on the guidance provided by the California Governor’s Office of Planning and Research (OPR) in the publication Transportation Impacts (SB 743) CEQA Guidelines Update and Technical Advisory, 2018. In June 2020, MCOG accepted the Senate Bill 743 Vehicle Miles Traveled Regional Baseline Study, which includes a recommended methodology and thresholds for VMT analysis for use in Mendocino County. Since the City of Willits has not yet adopted VMT thresholds, the MCOG methodology was used to analyze the potential impacts of the Sanhedrin Timber Company Entitlements Project
As described in the Technical Advisory and CEQA Guidelines Section 15064.3, “vehicle miles traveled refers to the amount and distance of automobile travel attributable to a project.” The Technical Advisory indicates “the term ‘automobile’ refers to on-road passenger vehicles, specifically cars and light duty trucks.” Accordingly, the Regional Baseline Study adopted by MCOG does not include VMT thresholds related to heavy-duty trucks; therefore, no VMT analysis was conducted regarding the minor modification of truck operations. While heavy truck trips are excluded from VMT analysis, it is noted that the project is not expected to increase trips on peak days and the purpose of the project is to increase operational efficiencies for the applicant. The project is expected to reduce the number of truck trips between Eureka and Willits, resulting in a beneficial impact on greenhouse gas (GHG) emissions, which supports the intent of SB 375.

Conclusions and Recommendations
 The proposed project would be expected to generate no new trip ends per day for either employees or trucks.
 Both existing driveways have adequate sight distance. Left turns would be accommodated at Casteel Lane, which is served by an existing two-way left-turn lane. A left-turn lane is not warranted at the Quail Meadow driveway.
 On-site circulation is expected to operate acceptably for all types of vehicles, including emergency responders.
 The project would be expected to have a less-than-significant impact on VMT.

We hope this information adequately addresses any questions regarding the project’s potential transportation impacts. Thank you for giving us the opportunity to provide these services.

Sincerely,
Dalene J. Whitlock, PE, PTOE
Senior Principal
DJW/djw/WIL052-1.L1
Enclosures: Counts, Left-turn Lane Warrant Spreadsheets Day: City: Willits
Date: Project #: CA23_080125_001

NB SB EB WB
2,407 2,311 00
AM Period NB SB EB WB NB SB EB WB
0:00 1 2     3 32 30     62
0:15 3 3     6 35 38     73
0:30 3 2     5 36 49     85
0:45 5 12 3 10 8 22 44 147 42 159 86 306
1:00 2 1     3 47 28     75
1:15 0 0     0 34 41     75
1:30 0 3     3 32 40     72
1:45 0 2 2 6 2 8 38 151 43 152 81 303
2:00 0 3     3 44 25     69
2:15 1 1     2 46 39     85
2:30 2 0     2 44 44     88
2:45 0 3 3 7 3 10 44 178 42 150 86 328
3:00 2 1     3 62 26     88
3:15 0 0     0 54 49     103
3:30 2 0     2 52 49     101
3:45 1 5 4 5 5 10 49 217 53 177 102 394
4:00 1 1     2 48 43     91
4:15 1 3     4 37 40     77
4:30 9 8     17 39 53     92
4:45 3 14 4 16 7 30 41 165 51 187 92 352
5:00 4 4     8 52 58     110
5:15 9 2     11 46 72     118
5:30 13 6     19 51 52     103
5:45 14 40 9 21 23 61 33 182 60 242 93 424
6:00 22 11     33 32 46     78
6:15 31 15     46 23 50     73
6:30 37 16     53 38 51     89
6:45 41 131 13 55 54 186 33 126 36 183 69 309
7:00 48 11     59 33 29     62
7:15 60 23     83 19 26     45
7:30 68 27     95 22 25     47
7:45 59 235 47 108 106 343 23 97 30 110 53 207
8:00 54 34     88 24 21     45
8:15 45 40     85 19 31     50
8:30 38 36     74 15 16     31
8:45 34 171 38 148 72 319 11 69 14 82 25 151
9:00 32 29     61 12 14     26
9:15 29 33     62 8 13     21
9:30 36 35     71 6 13     19
9:45 32 129 30 127 62 256 13 39 11 51 24 90
10:00 26 24     50 12 6     18
10:15 28 40     68 13 9     22
10:30 27 32     59 6 5     11
10:45 33 114 39 135 72 249 3 34 7 27 10 61
11:00 29 35     64 3 5     8
11:15 32 35     67 3 3     6
11:30 40 36     76 4 4     8
11:45 32 133 32 138 64 271 3 13 3 15 6 28
TOTALS 989 776 1765 1418 1535 2953
SPLIT % 56.0% 44.0% 37.4% 48.0% 52.0% 62.6%

NB SB EB WB
2,407 2,311 00
AM Peak Hour 7:15 7:45 7:30 15:00 17:00 17:00
AM Pk Volume 241 157 374 217 242 424
Pk Hr Factor 0.886 0.835 0.882 0.875 0.840 0.898
7 ‐ 9 Volume 406 256 00 662 347 429 00 776
7 ‐ 9 Peak Hour 7:15 7:45 7:30 16:45 17:00 17:00
7 ‐ 9 Pk Volume 241 157 0 0 374 190 242 0 0 424
Pk Hr Factor 0.886 0.835 0.000 0.000 0.882 0.913 0.840 0.000 0.000 0.898 VOLUME
Prepared by NDS/ATD
13:15
13:30
13:45
12:00
12:15
12:30
12:45
13:00
16:15
16:30
14:00
14:15
14:30
4/26/2023
14:45
15:00

DAILY TOTALS
PM Period
16:45
17:00
17:15
Wednesday
17:30
17:45
15:15
15:30
15:45
16:00
18:00
18:15
18:30
18:45
19:00
19:15
N Main St N/O Casteel Ln
21:30
21:45
22:00
Total
4,718
19:30
19:45
20:00
20:15

DAILY TOTALS
22:15
22:30
22:45
23:00
23:15
23:30
TOTAL
23:45
TOTALS
Total
4,718

DAILY TOTALS
21:00
21:15
20:30
4 ‐ 6 Peak Hour
4 ‐ 6 Pk Volume
SPLIT %
TOTAL
Pk Hr Factor
PM Peak Hour
PM Pk Volume
Pk Hr Factor
4 ‐ 6 Volume
20:45
(veh/hr) (veh/hr)
241 157
15 Northbound Speed Limit: 35 mph Southbound Speed Limit: 35 mph Northbound Configuration: Southbound Configuration:

1. Check for right turn volume criteria %lt 8.7 %
AV 674 veh/hr

2. Check advance volume threshold criteria for turn lane AV = 1050.1
Va = 241
No
NO
Right Turn Taper Warrants

1. Check taper volume criteria

2. Check advance volume threshold criteria for taper
AV = - Study Intersection
NO NO
= Through Volume
North Main Street
Right Turn Taper Warranted: Left Turn Lane Warranted:
(evaluate if right turn lane is unwarranted)
Va = 241 mph
Right Turn Lane Warranted:

If AV<Va then warrant is met
Advancing Volume
Turn Lane Warrant Analysis - Tee Intersections
Direction of Analysis Street: Cross Street Intersects:

The left turn lane analysis is based on work conducted by M.D. Harmelink in 1967, and modified by Kikuchi and Chakroborty in 1991.

Advancing Volume Threshold
Advancing Volume Threshold
The right turn lane and taper analysis is based on work conducted by Cottrell in 1981. -
Methodology based on Washington State Transportation Center Research Report Method For Prioritizing Intersection Improvements , January 1997.

Through Volume =
Turn lane warranted if point falls to right of warrant threshold line Two lane roadway warrant threshold for: 35
NOT WARRANTED - Less than 20 vehicles
If AV<Va then warrant is met
Advancing Volume
Project Driveway
Percentage Left Turns
If AV<Va then warrant is met
Southbound
Advancing Volume Threshold
2 Lanes - Undivided
Northbound
Thresholds not met, continue to next step
Northbound Volumes Southbound Volumes
Right Turn Lane Warrants Left Turn Lane Warrants
Right Turn Volume = = Left Turn Volume
2 Lanes - Undivided
Northbound
North Main Street
Study Intersection: North Main Street/Project Driveway
Study Scenario: Existing plus Project AM Peak Hour
North/South From the East
y = -868.7ln(x) + 5898.6 100
200
300
400
500
600
700
800
900
1000
0 200 400 600 800 1000
Opposing Volume (Vo)
Advancing Volume (Va)
W-Trans 5/15/2023
(veh/hr) (veh/hr)
217 242
15 Northbound Speed Limit: 35 mph Southbound Speed Limit: 35 mph Northbound Configuration: Southbound Configuration:

1. Check for right turn volume criteria %lt 5.8 %
AV 857 veh/hr

2. Check advance volume threshold criteria for turn lane AV = 1050.1
Va = 217
No
NO
Right Turn Taper Warrants

1. Check taper volume criteria

2. Check advance volume threshold criteria for taper
AV = - Study Intersection
NO NO
Turn Lane Warrant Analysis - Tee Intersections
Study Intersection: North Main Street/Project Driveway
Study Scenario: Existing plus Project PM Peak Hour
Direction of Analysis Street: North/South Cross Street Intersects: From the East Northbound Right Turn Lane Warrants Southbound Left Turn Lane Warrants North Main Street North Main Street
Northbound Volumes Southbound Volumes
Through Volume = = Through Volume
Right Turn Volume = = Left Turn Volume
2 Lanes - Undivided Project Driveway 2 Lanes - Undivided Percentage Left Turns
Advancing Volume Threshold
Thresholds not met, continue to next step If AV<Va then warrant is met Advancing Volume Threshold
Advancing Volume
If AV<Va then warrant is met
Right Turn Lane Warranted:

Northbound
(evaluate if right turn lane is unwarranted)
NOT WARRANTED - Less than 20 vehicles
Advancing Volume Threshold
Advancing Volume Va = 217 Two lane roadway warrant threshold for: mph If AV<Va then warrant is met - Turn lane warranted if point falls to right of warrant threshold line 35 Right Turn Taper Warranted: Left Turn Lane Warranted:

Methodology based on Washington State Transportation Center Research Report Method For Prioritizing Intersection Improvements , January 1997.

The right turn lane and taper analysis is based on work conducted by Cottrell in 1981.

The left turn lane analysis is based on work conducted by M.D. Harmelink in 1967, and modified by Kikuchi and Chakroborty in 1991. y = -868.9ln(x) + 6084.4 100
200
300
400
500
600
700
800
900
1000
0 200 400 600 800 1000
Opposing Volume (Vo)
Advancing Volume (Va)
W-Trans 5/15/2023
Revised Draft CEQA Initial Study
City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025

A P P E N D I X F
N a t i v e A m e r i c a n H e r i t a g e C o m m i s s i o n S a c r e d L a n d s F i l e S e a r c h a n d C o n t a c t L i s t
STATE OF CALIFORNIA Gavin Newsom, Governor

NATIVE AMERICAN HERITAGE COMMISSION